BlueWave Solar 45 Oak St, Douglas Project

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The Project:

The 45 Oak Street, Douglas solar project is one of 5 solar projects of BlueWave, a Boston-based company owned by a Canadian firm, Axium Infrastructure, which raised $91 million in equity and debt to finance five agrivoltaic projects across Massachusetts.

BlueWave secured approval in 2020 for a 3.5 MW array on approximately 20 acres at 45 Oak St in Douglas. Construction is to be conducted in three phases with an expected finish before the end of 2023. The BlueWave site has a dual-use goal of supplying solar energy and as an agricultural operation of sheep or goat farming under the solar arrays.

With entrance at 45 Oak St. Douglas, the site straddles the Manchaug Pond Watershed at the north side of the property, Stevens Pond Watershed on the south and Whitins Reservoir Watershed is a short distance south on Oak Street.

Worcester Business Journal Article. September 15, 2023

BlueWave Solar Construction Site, 45 Oak St, Douglas with Manchaug Pond in distance. 2024, February 24 (Photo by recreational drone flyer High Octane Image-High Performance

Report Environmental Impacts to:

Town of Douglas: Community Development Director Matt Benoit 508-476-4000 xt. 206 or mbenoit@douglas-ma.gov, Conservation Agent Brandon Faneuf bfaneuf@douglas-ma.gov

Town of Sutton Conservation Commission:  508-865-8728  Secretary Wanda Bien or Conservation Agent Brandon Faneuf bfaneuf@ecosystem-solutions.com

Town of Sutton Health Dept./Board of Health: 508-865-8724

MassDEP Wetlands: Thomas Rebula  Thomas.Rebula@mass.gov

Attend a Meeting ~ Links to Agendas & More

Weds., April 17th - Sutton Conservation Commission. 6:30 p.m.  Zoom Link

Mon., April 22 - Douglas Conservation Commission. 7 p.m.

Manchaug Pond Foundation

Manchaug Pond Watershed Map

The Documents

Truck Traffic/Material Trucked in:

between 5/2023 to 1/23/2024 -514 loads and 13,031.99 tons

Hylka Construction Letter of Materials

BlueWave Solar Material spreadsheet 5-2023 to 1-23-2024

BlueWave On-site Testing Results

PFAS Chemical Testing Results:  6 out of 40 found at Basin 5 construction site PFAS Testing Results_45 Oak Street_3-5-24 (1)

Soil Testing Results: Table 1 - Surficial Soil Analytical Results 2024.01.15

Required Restoration of impacted areas to be completed by BlueWave Solar

3/11/24 Diver activity from dam to ramp area only- No report received

As of March 22, 2024 ~ World Water Day

  • No water quality testing and monitoring: ecoli, turbidity, total phosphorus, DO, etc.
  • No sediment removal from Manchaug Pond, Stevens Pond or the Mumford River
  • No restoration of wetland which was improved by Manchaug Pond Foundation s319 NPS Pollution Grant
  • No cleaning of debris from roadsides or catch basins nor reimbursement to the Town of Douglas for cleaning, modification and repair.
  • No sediment removal from neighbors forested land and wetlands property owner yet to be contacted for permission to inspect
  • No follow-up PFAS testing of impacted waters and fish

What People Are Saying ~ TESTIMONY SUBMITTED

Adam, Kautza, Coldwater Fisheries Project Leader, Massachusetts Division of Fisheries and Wildlife, January 19, 2024, UNT Coldwater Fishery to Manchaug Pond, Douglas.

Senator Ryan Fattman & Rep. Joseph McKenna to Douglas Board of Selectman Chair Kevin Morse and Sutton Select Board Chair Jonathan Anderson, February 21, 2024, BlueWave Solar and The Douglas and Sutton Conservation Commissions.

The Construction Site Problems:
  • Cutting of the forested acreage of the 20+ acre site
  • Incomplete and unstabilized phases of construction
  • Removal of topsoil exposing subsoils of clay and hardpan
  • Trucking in over 13,000 tons of additional clay, silt, stone, and riprap
  • Repeated failure of erosion control measures resulting in numerous and repeated sediment, runoff, and erosion events of sediment and sediment-laden water discharge into abutting properties, the Oak Street neighborhood, and wetlands on Holt and Torrey Roads, Sutton, Manchaug Pond, Stevens Pond and the Mumford River and into the Whitins Reservoir watershed.
  • Design failure of the three partially constructed infiltration basins resulting in regular pumping of collected sediment-laden water of basins 1, 2, and 5 with discharge onto abutting properties. Pumping results in sediment runoff and significant discharged to Oak Street, Douglas and Torrey Rd, Sutton in Manchaug Pond watershed and drying of wetlands in Stevens Pond watershed.
The Environmental Impact:

 

IMPACT AREA - EROSION, SEDIMENT, RUNOFF, FILLING WETLANDS, & PUMPING DISCHARGE :

July 2023 to Present

  • Oak St., Douglas
  • Holt Rd., Sutton
  • Parker Ct., Douglas
  • Wetlands, Holt Road, Sutton
  • Manchaug Pond, Sutton/Douglas
  • Stevens Pond, Sutton
  • Mumford River, Manchaug
  • Private Properties on Oak Street, Douglas
  • Private Properties on Torrey Rd, Sutton
  • Manchaug Pond watershed
  • Stevens Pond watershed.

2023, December 11. Manchaug Pond south-east end brown from sediment runoff from BlueWave Solar Construction Site at 45 Oak St Douglas

December 18, 2024 Sediment runoff into Manchaug Pond from BlueWave Solar Construction Site

January 10, 2024. Wetlands,  Holt Road, Sutton. Sediment and sediment-laden water runoff/erosion from BlueWave Solar 45 Oak Street, Douglas Solar Construction Site. Manchaug Pond/Mumford River/Blackstone River Watershed

January 10th: Turbity curtain ineffective as not installed/anchored or cleaned/maintained. Manchaug Pond southeast cove as 45 Oak St Solar site Infiltration Basin 5 failure results in significant runoff, erosion and sediment-laden water flooding Holt Rd wetland, Holt Rd and lake.

January 13th Pumping discharge from failed Infiltration Basin 2 dumping sediment-laden water through neighbor's property to Oak Street

Pumping Sediment-Laden Water Off-site to Abutters:  Ongoing

  • Ongoing pumping of sediment-laden water from failed infiltration basins offsite to neighborhood yards, driveways and roadsides causing flooding, erosions and washouts.
  • Entrance driveway runoff of sediment-laden water flowing across and down Oak St and to Holt Road Sutton and beyond to Parker Ct, Douglas. Required cleaning of 4 catch basins, addition of berm at lower catch basin,  and patching of road to handle the increase flow.
  • Oak St flowing southwest towards the coldwater fishery stream and northeast downhill toward coldwater fishery stream and Manchaug Pond
  • Pumping to the east to abutting properties on Torrey Rd.

April 2024

April 12

April
MARCH 2024
March 29
March 23
March 3

Oak St Solar Entrance March 3, 2024 Sediment-laden water on Oak St

Sediment in Manchaug Pond from 45 Oak St runoff March 3, 2024

Sediment visible in Mumford River March 3, 2024 from Parker Rd between Manchaug and Stevens Ponds

JANUARY 2024

January 12 & 13:

  • Light rainfall resulted in sediment-laden water flowing offsite down to Holt Rd wetlands, Manchaug Pond, Stevens Pond and Mumford
  • Pumping of basin 5 resulted in sediment-laden water discharged to 78 Torrey Rd (see Facebook video)

January 10, 2024

  • Light rainfall resulted in sediment-laden water to Holt Rd wetlands, Manchaug Pond, Stevens Pond and Mumford

January 10th: Manchaug Pond southeast cove as 45 Oak St Solar site Infiltration Basin 5 failure results in significant runoff, erosion and sediment-laden water flooding Holt Rd wetland, Holt Rd and lake with turbidity curtains ineffective.

January 13: Manchaug Pond's southeast cove fully flooded and impacted with sediment.

Oak St Solar Entrance January 26, 2024

DECEMBER 2023

December 22, 2023 at 10:00 a.m. Mumford River, Sutton below Stevens Pond Dam. Sediment and Sediment-laden water Runoff/erosion in to Manchaug Pond flowing to Stevens Pond and greater Mumford River from Bluewave Solar 45 Oak Street, Douglas Solar Construction Site.

December 21, 2023

  • Town of Douglas Highway Dept. removes 5 ton of sediment from 4 Oak St Catch Basins as requested by the Conservation Commission.  Total $796.32.

December 22, 2023:

  • Sediment-laden waters flowing from Manchaug Pond, Stevens Pond and after the Stevens Dam in the greater Mumford River

December 18, 2023:

  • Continued failure of Infiltration Basin 5 area/NW corner with significant sediment and sediment-laden waters discharged into abutting woods flowing 1300 feet down to Holt Rd, Sutton wetlands, south eastern area of Manchaug Pond from causeway to dam, Stevens Pond and Mumford River
  • Continued pumping of Infiltration Basin 2 into silt-sack discharging sediment-laden water to BVW, swale, 41-45 Oak St, 42 Oak to woods behind house, down Oak St to Holt Road Sutton to Parker Ct. Douglas
  • Runoff from site entrance down Oak St to Holt Rd Sutton and to Parker Rd, Douglas

December 11, 2023:

  • Failure of Infiltration Basin 5 at northeast corner of site resulting in overtopping with significant erosion of clay and silt resulting in sediment-laden waters flowing 1,300 feet off site to abutters woods, downn 200 ft elevation to wetlands and Holt Rd, Sutton, and Manchaug Pond from dam to causeway. Flow out dam carried to Stevens Pond and greater Mumford River
  • Infiltration Basin 2 pumped into silt-sack discharging sediment-laden water to bordering vetetated wetlands, swale, 41-45 Oak St, 42 Oak to woods behind house, down Oak St to Holt Road Sutton to Parker Ct. Douglas (see Facebook for videos and photos)
Enforcement Action by Towns

The Town of Sutton Conservation Commission was the first to take action requiring BlueWave Solar to cease and desist from the activity affecting Manchaug Pond and the Holt Road wetlands and requiring a plan by the company to restore the area affected.

Douglas Conservation Commission, Planning Board and the Board of Selectman took action with Enforcement Order and call for redesigns of failed Infiltration Basins 1, 2 and 5.

April 1, 2024: DOUGLAS CONSERVATION COMMISSION Votes 3 to 1

  • Lift Enforcemnt Order but adding a new condition requiring Phases 1, 2 and 3, including peer review of Infiltration Basine 1 and 5 are resolved and stablized beofre Phase 4 can begin.
  • March 20, 2024: SUTTON CONSERVATION COMMISSION Votes

  • Extend fine of $300 /day for a period of 90 days.
  • January 2024: DOUGLAS Planning Board

  • Re-design of Infiltration Basin 1 as not draining and excessive runoff from driveway to Oak St., Douglas
  • January 12, 2024: DOUGLAS CONSERVATION COMMISSION Request

  • As-built/progress plan of Infiltration Basin 5 (and verbal offer of Basins 1 and 2)
  • Improve good-housekeeping practices extending stone construction entrance deeper into site so dirt does not enter road
  • Prevent additional water and sediment-laden water from exiting the site, including point-source discharges like those from the Infiltration Basins and diversion ditch
  • Require PFAS testing of soils imported to the site and currently on-site

  • January 8, 2024: Enforcement order Issued by DOUGLAS CONSERVATION COMMISSION

  • $200/Day fine
  • "Shall immediately cease and desist from any activity affecting the buffer zone and/or resource areas."
  • A Restoration Plan shall be filed with the issuing authority on or before 2/12/2024"
  • As- Built/Progress Plan of Infiltration Basin 5 (and verbal offer of Infiltration Basins 1 and 2)
  • Improve good-housekeeping practices extending stone construction entrance deeper into site so dirt does not enter road
  • Prevent additional water and sediment-laden water from exiting the site, including point-source discharges like those from the infiltration basins and diversion ditch
  • Require PFAS Testing of soils imported to the site and currently on-site
  • Resource area alterations resulting from said activity shall be corrected and the resource areas returned to their original condition
  • January 3, 2024: Restoration Plan V.3 submitted to Sutton/Douglas CONSERVATION

    • Documents December 10 and 11th sedimentation events and December 27-28 failure of Infiltration Basin #5 by overtopping, failure of sediment/erosion control barriers
    • Identifies 45 Oak St, Douglas and 25R Holt Road, Sutton as "Heavy Impact" with other parcels and water resources as only "possible impact"
    • Proposed Restoration Plan
      • Pre-Restoration
      • Soil Deposition Removal with the Upland, Wetland and Intermittent Stream
      • Sediment Removal Within Manchaug Pond

    December 20, 2023: Enforcement Order Issued by Sutton Conservation Commission

    • “Shall immediately cease and desist from any activity affecting the Buffer Zone and/or resource areas.
    • Resource area alterations resulting from said activity shall be corrected and the resource areas returned to their original condition
    • A restoration plan shall be filed with the issuing authority on or before 1/2/2024”

    In Jeopardy:

    Coldwater Fishery & Manchaug Pond's Southwest Cove:

    • a woodland stream on private lands is habitat for native Eastern Brook Trout and brings fresh water to Manchaug Pond's southwest cove.

    LETTER: Adam, Kautza, Coldwater Fisheries Project Leader, Massachusetts Division of Fisheries and Wildlife, January 19, 2024, UNT Coldwater Fishery to Manchaug Pond, Douglas.

    Manchaug Pond Foundation has testified to both towns the urgency, arranged a site visit with the Conservation agent, staff and a Sutton Conservation Commissioner participating, and has secured a follow-up survey of the stream by MassWildlife to access it's health for summer 2024.

    More on the subject of solar, climate, and protecting our natural resources...

    BMPs for Solar Installations -  Preserving Nature, Forests & Farmland

    Growing Solar, Protecting Nature. Massachusetts Audubon and Harvard Forest, October 2023.

    Large-Scale Solar Installations Position Paper and Resource Guide for Town Officials. Blackstone River Watershed Association, October 9, 2018.

    Coldwater Fisheries

    Mass Fisheries and Wildlife. Coldwater Fish Resources.

    Russ Cohen, Rivers Advocate. Mass Dept of Fish and Game, Division of Ecological Restoration. 10 Ways Conservation Commissions And Others Can Protect Coldwater Streams and Their Inhabitants. Sea Run Brook Trout Coalition. July 10, 2017.

    Glen Krevousky & Russ Cohen. EBT Environmental, Inc. Additional Opportunities to Protect Trout Streams in the Commonwealth. Website Page

    Jason Dunham, US Forest Service. Chapter 8. Coldwater Fish in Wadeable Streams. 2009.

    The "Forever Chemicals" - PFAS

    Mass Department of Energy and Enviromental Affairs Data Portal. State testing in 2022 of public water supplies found NO PFAS at Manchaug Pond campgrounds

    Mass Dept of Environmental Affairs. Per- and Polyfluoroalkyl Substances (PFAS)

    Mass Dept. of Public Health. PFAS Fish and Surface Water Surveillance

    Various PFAS Presentations & Webinars on YouTube.
    Mass Department of Environmental Protection (MassDEP),  Www.youtube.com/@MassDEP.

    What are PFAS? Waterkeeepers Alliance website.


    ...most importantly, cutting forests and developing farmlands to build solar energy doesn’t make sense for the climate: natural ecosystems and farm soils absorb 10% of Massachusetts’ greenhouse gas emissions every year.
    Massachusetts Audubon

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