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Several Fryeburg citizens asked the Friends of Sebago Lake (FOSL) to review and comment on the conclusions of two Fryeburg environmental water studies; one by Emery and Garrett Groundwater Inc. 2005, and the second by Normandeau Associates, December, 2007. Friends of Sebago Lake has 18 years of experience with regulatory agencies and the environmental impacts of unnatural lake and river regulation. Many FOSL publications and letters can also be viewed on elibrary of the Federal Energy Regulatory Commission website
Comments
The two studies EGGI (Wards Brook) and Normandeau Associates, Inc.
(Lovewell Pond) conclude the volume of water extraction from the Ward’s
Brook Aquifer has no significant impact to Lovewell Pond. Friends of
Sebago Lake believes that limnology, pertaining to the study of lakes,
is a very complicated science. Each lake is different and the impacts of altering the hydrologic flow will vary from lake to lake. There are many different variables that
would affect the impacts on Lovewell Pond of groundwater extraction in the
Lovewell Pond watershed such as water temperature, stratification, water level range, seasonal timing of lake water level fluctuations, precipitation, outlet and lake bathymetry, groundwater lake charge, evaporation volume, and lake inflow volumes. These variables are not addressed or receive insufficient discussion in the two studies. Friends of Sebago Lake believes these studies are inadequate for any meaningful conclusions either for determining safe volumes of groundwater extraction
or impacts to Lovewell Pond.
Several study factors or statements listed below create questions about
the accuracy of the EGGI and Normandeau conclusions.
* For precipitation amounts and timing of those events during the study
time period it was an atypical year.
* Missing data - A flow meter installed for collecting data at outlet of
Wards Brook failed to perform.
* The “no significant impact” statement in the EGGI conclusions refers to
volume of water ratio of Wards Brook flow to Saco river flood input and
the studies do not mention ecological impacts during low flow months of summer.
* Neither the EGGI or Normandeau study addresses impacts of temperature
changes in Lovewell Pond due to reduced Wards Brook flow and groundwater charge.
* Neither EGGI nor the Normandeau study addresses increased summer
stagnation in Ward’s brook outlet and Lovewell Pond due to reduced
tributary flow especially in the shallower northern end.
* Not one lake scientist either from Maine DEP or Maine Geological
Services has stated publicly that the present level of groundwater
extraction would not significantly impact temperature of Lovewell Pond or
the stagnation rate during the low flow months of summer.
* The maps of the boundaries of the aquifer and flow in it are merely
guesses. Expensive test well studies are needed to determine accurate
details of the aquifer and groundwater flow to Lovewell Pond.
* Normandeau conclusions supporting insignificant impact of groundwater
extraction are based on the misunderstanding between EGGI and Maine DEP .
Discussion
A significant time frame of the study was from June 2006 to July
2007. Precipitation was “atypical”. Water flows were abnormally higher
during the summer and lower in the winter. Usually , it is the opposite
case where tributary flows are lower in the summer. Flow volume data
gathered during this time period would not provide any relevance for
groundwater extraction impact conclusions for Lovewell Pond. The study
fails to address temperature changes to Lovewell Pond. The Normandeau
study states the amount of water entering the lake from the river on an
annual basis is two and one half times the volume of the lake. This back
filling of the lake by the rising Saco River occurs typically in the
spring or sometimes in the late fall. This river water is significantly
higher in phosphorus nutrients than the groundwater that is extracted and
would have entered the pond according to the study. However, phosphorus
and other nutrients and biota relationships are very sensitive to even
small changes in water temperature of the preferred temperature range of a
species. The more phosphorus the more important temperature is to the ratio
of biomass production. As the water temperature rises there can be an
exponential rise in biological activity. The study emphasizes the high
phosphorus content of the river water. Normandeau goes into considerable
detail on formulating phosphorus contributions for Ward’s brook and the Saco.
However, the Normandeau study does not address the stagnation of Lovewell
Pond water in the drier summer and early fall months when the Pond is
mostly dependent on water inflow from spring seeps and Wards Brook to
mitigate stagnation and maintain a lower water temperature. Even a couple
of degrees of temperature rise can greatly impact biological activity and
phosphorus transfer. In a drought year the impact of water extraction
would have a more harmful impact. In a normal rainfall year the impact
would be less severe but could be highly significant. Friends of Sebago
Lake (FOSL) disagrees with the Normandeau support of the conclusion of the
2005 EGGI study. FOSL believes the EGGI study conclusions are flawed.
The EGGI study stated that the water withdrawals would have an insignificant
impact on Lovewell Pond. Since EGGI performed no studies on Lovewell Pond it was unscientific and improper for EGGI to formulate this conclusion. According to their report, the EGGI staff received input on Lovewell Pond from Gene Berghoffen of the
Planning Board, Howard Dearborn, Denny McNish of IF&W and Linda Bacon,
a lake biologist with the Maine DEP. Howard Dearborn has stated many times
in meetings and in newsletters that the withdrawals are damaging Lovewell
Pond. Gene Berghoffen was the planning board chairman during the study
period. Berghoffen’s present area of expertise is in the field of trucking
management systems. For EGGI to base their conclusion on the statements of
two local citizens would be unusual for a professional consulting firm.
From what FOSL can interpret there was a misunderstanding between EGGI
and Linda Bacon, a DEP lake biologist. FOSL believes Bacon did say to
EGGI that the amount of water extracted from the aquifer in relation to
the amount of water that annually enters the lake from the river is
insignificant. No evidence exists that EGGI ever discussed with Bacon the
impacts of spring water extraction on Lovewell Pond in the low flow warm
months of June, July, August and September when the only significant
inflow to Lovewell Pond is Ward’s Brook and spring seeps. This is a major
omission in the justification of the present extraction. It is very
disappointing that with all the resources and time that have been expended
for these two studies there is so much doubt of their scientific
correctness.
Roger Wheeler
Friends of Sebago Lake
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