Navigating the Draft Deer Island NPDES Permit: Protecting MWRA’s Sewer Communities


Recently, the Environmental Protection Agency (EPA) released the draft Deer Island National Pollutant Discharge Elimination System (NPDES) permit, raising concerns about potential negative impacts on MWRA’s sewer communities. This post highlights the urgency of active community engagement and emphasizes the need to address these concerns effectively.

Addressing Concerns and Collaborative Efforts

Last week, MWRA staff presented critical information on the draft NPDES permit to the MWRA Board of Directors followed by the Advisory Board’s Operations Committee. Accompanied by our special counsel, Beveridge & Diamond, MWRA reviewed with the Operations Committee the potential impacts on MWRA’s sewer communities. All 43 MWRA wastewater communities have been named co-permittees, which would make it the largest NPDES permit to do so in the nation.

Uncertainties and Gray Areas

While EPA’s draft permit acknowledges some of the Advisory Board’s concerns, uncertainties remain, necessitating further clarification. To address these, the Advisory Board, along with its special counsel and MWRA’s legal team, convened to coordinate comments on the permit. Of particular concern are the climate change resiliency requirements, which could strain communities by diverting crucial resources and funds.

The Balancing Act: Climate Change Resiliency and the NPDES Permit

The Advisory Board acknowledges the importance of combating climate change but plans to raise questions regarding the suitability of the NPDES permit for implementing these requirements as part of its comments. Striving for a “Green and Fair” approach, we prioritize environmentally sound initiatives while ensuring costs remain ratepayer equitable. Striking this balance is vital for both environmental stewardship and the welfare of MWRA’s sewer communities.

Taking Action and Community Outreach

Active participation from MWRA’s sewer communities is essential to protect their interests. Submitting comments during the 90-day comment period is crucial to preserve the right to appeal in future. Beveridge & Diamond will provide comprehensive comments as a resource for communities, which they can tailor to address their unique concerns. Furthermore, the Advisory Board staff will launch an aggressive outreach campaign, ensuring all 43 sewer communities are informed and equipped to submit their comments promptly.


As the MWRA Advisory Board navigates the draft Deer Island NPDES permit, safeguarding the interests of MWRA’s sewer communities is of paramount importance. Collaborative efforts, community engagement, and addressing potential negative impacts are central to achieving the best possible outcome in the final Deer Island NPDES permit. By prioritizing the welfare of sewer communities and advocating for a “Green and Fair” approach, we can strike a balance between environmental responsibility and the fiscal well-being of MWRA’s sewer communities. Active involvement from all stakeholders is crucial in shaping the final NPDES permit and ensuring a sustainable future for MWRA’s sewer communities.