Chairman Resor, Chairman Greene, and Members of the Committee:

My name is Pamela DiBona, I am Vice President for Policy at the Environmental League of Massachusetts. The Environmental League strongly supports S. 1252, which would reduce some of the costs associated with cleaning up our rivers and lakes.

The Problem
In unpolluted freshwater rivers, lakes, and ponds, nutrients such as phosphorus and nitrogen are present in very low concentrations; the scarcity naturally limits aquatic plant and algal growth. Nutrient loading (of phosphorus and nitrogen) from wastewater treatment plants and stormwater runoff allows algae and aquatic plants to grow prolifically. Several rivers and streams in Massachusetts, including the Assabet, the Concord, the Blackstone and the Charles, are eutrophic during the summer months, that is the waters are clouded by algal blooms and/or blanketed with aquatic plants. Boating, fishing and swimming are unappealing or impossible. The plant growth can also harm fish and other aquatic life by causing dramatic daily variations in the amount of dissolved oxygen available in the water.

Besides being unsightly and interfering with activities like canoeing, this excessive vegetative productivity also has a more subtle effect. As plants grow they take up soluble phosphorus, then they die and the decaying plant material deposits particulate phosphorus on the river bottom. These organic sediments slowly fill in the impoundments and create a very large source of phosphorus. This phosphorus source could potentially cause release phosphorus back into the river for a very long time even if all phosphorus sources to the river were eliminated. These potential long-term problems mean that time is of the essence - delaying now will substantially lengthen the recovery time of the rivers.

The primary point source of phosphorus to the river is from domestic wastewater treatment facilites (WWTFs). The WWTF phosphorus load has a particularly negative effect because the phosphorus is primarily in the form of othophosphate, which is the most available form for aquatic growth, and the discharge is continuous, so the impact is augmented in the summertime when river flows are low and aquatic growth is fast due to favorable weather.

To restore our rivers and protect habitat, wastewater treatment plants will need to meet increasingly stringent and costly phosphorus limits in the future. However, there are few cost effective ways to lower effluent limits, at least not in the near future. A more immediate, and less costly method, is to reduce the source load to the WWTFs. Reduction of phosphorus loads at their source will help keep treatment costs down for municipalities and improve local rivers.

Sources of Phosphorus at Wastewater Treatment Plants
The major sources of phosphorus entering a municipal wastewater treatment plant are typically human waste, food waste (washed down the sink), automatic dishwashing detergents, and polyphosphates used by municipal water departments to control corrosion in water supply systems. Phosphorus may also be introduced to the sewer system from industrial sources such as food processing or manufacturing plants. Currently, automatic dishwashing detergents and several other cleaning products may contain up to 8.7 percent phosphorus by weight. The Massachusetts Department of Environmental Protection has estimated that between 8% and 17% of the phosphorus load to wastewater treatment plants from domestic sewage comes from automatic dishwashing detergents. The Charles River Watershed Association's engineers think it is more like 9 to 34%. Either way, this translates into thousands of pounds of phosphorus sent to Massachusetts' wastewater treatment plants each year.

Part of the solution
Non-phosphate automatic dishwashing detergents are now available in Massachusetts supermarkets and specialty stores, and from online distributors. Industry representatives have argued that the products don't work. I and many of my friends have cabinets full of clean dishes that counter their argument. And this bill provides for continued use in commercial settings, avoiding concerns about sanitation in hospitals and food processing. In the end, by requiring that automatic dishwashing detergents contain no more than trace amounts of elemental phosphorus, Senate Bill 1252 could reduce phosphorus loading to the Commonwealth's surface waters by as much as 34%, representing a significant saving for our municipalities as they work to remove phosphorous from their treatment plant discharges.