MEMORANDUM

To: David Terry, Director of Drinking Water Program, Massachusetts Department of Environmental Protection

From: Environmental League of Massachusetts

Date: December 8, 1998

The Environmental League of Massachusetts (ELM) is writing to comment on DEP’s filtration determination for Wachusett Reservoir. ELM has followed the debate closely and wishes to recognize the diligence and creativity of the state, particularly the Massachusetts Water Resources Authority (MWRA), in working to provide safe drinking water. Despite the significant progress toward improving the MWRA system including the implementation of watershed protection measures, construction of interim disinfection facilities, and covering of open distribution reservoirs, there remain significant concerns about the quality and safety of the drinking water supplied to MWRA consumers. We, therefore, believe that a filtration system should be installed at the Wachusett Reservoir.

In terms of the specifics of compliance, because of conflicting data and time frames, we feel there is some question as to whether the MWRA is meeting all eleven criteria at this time. Namely, it is unclear if the MWRA is consistently meeting the criteria for giardia and viruses and total coliform bacteria. In addition, even with the significant progress in terms of watershed protection efforts, there is still concern about existing development in the watershed and its impact on the reservoir.

Beyond our concerns regarding the specifics of compliance, there are several reasons why we feel that both filtration and aggressive watershed protection are necessary to provide clean, safe drinking water to all MWRA communities:

1. Drinking water is perhaps the most essential of our public goods, and as such, all communities have a right to clean, safe drinking water. Vulnerable populations – the elderly, the young, and the immune compromised – cannot take the risk of consuming water which, at best, has been erratically in compliance with the Surface Water Treatment Rule (SWTR). Only filtration in conjuction with source water protection, chemical disinfection, and a clean distribution system can provide the level of protection needed in the MWRA system to guard against the incidence of waterborne infectious disease.

In addition to the removal of bacteria, cryptosporidium and giardia, filtration will address two specific public health concerns: 1) it will limit the bacterial regrowth problem that ozonation alone may actually exacerbate; and 2) it will allow for use of lower levels of chlorine and ozone and thus limit exposure to carcinogenic disinfection byproducts. It is reasonable to pay an extra $22 per year to provide the extra margin of safety that affords all MWRA consumers access to safe drinking water.

2. Contrary to the findings of the Determination, the construction of the ozonation plant lays the groundwork for undermining watershed protection efforts, particularly on a local level. Simply put, those interests looking for a rationale for loosening land use restrictions can point to the construction of any type of treatment facility to support their position that strict watershed protection is unnecessary. This potential threat to watershed protection emphasizes the vulnerability of even the state’s most aggressive watershed protection plan. Hence, filtration is a necessary safeguard.

ELM wholeheartedly agrees with DEP that source water protection is fundamental to ensure a safe drinking water supply. As the Department mentioned in the Determination, "watershed protection is the first and most critical line of defense for maintaining the long-term health of the resource." Accordingly, the state has a laudable watershed protection plan in place which includes spending $8 million per year over the next five years to acquire lands in the Wachusett, Ware, and Quabbin Watersheds, a 10-year forest management plan, a Ranger program, and creative strategies for putting land in protected status. This watershed protection plan demonstrates vision and leadership by the state in not only protecting the drinking water supply, but also in preserving the ecological integrity of the region. With the state’s continued leadership on this issue the public will receive the benefits of the multi-barrier approach of both filtration and watershed protection.

In closing, we agree that clean source water is an important element of a safe water supply. But, even the best watershed protection program cannot guarantee a water supply free from pathogens. We, therefore, urge the Department to require the MWRA to proceed with the design and construction of a filtration facility and we urge the state to continue its exemplary leadership in implementing the Watershed Protection Plan for the Wachusett Watershed.