Moving from Rhetoric to Useful Information

Editorial by Executive Director Joe Favaloro

Following months of escalating rhetoric on both sides, it’s time to take a step back and assess what we need to do to move forward. If there is ever going to be a resolution to the off-trail activity debate, there needs to be a better understanding – on all sides – of all the impacts.

Ware River Watershed Management AreasWith this in mind, I strongly believe that any review of the Ware River Watershed public access plan must be preceded by a comprehensive study. The research, conducted by an independent third party, should investigate the issues in question: the impacts of unauthorized trail construction and off-trail activities.

The study should explore how these factors affect the core mission of DCR’s Division of Watershed Supply Protection and Office of Watershed Management, as well as how watershed stakeholders may be impacted, from all trail users, to MWRA customers, and even Ware River communities.

The study must look at the potential technical impacts, including water quality, forest management, and endangered species habitat.

Beyond the technical components, the study should dive into community impacts. What would be the enforcement and cost implications of changes to the access plan?

The study should also establish the context for this debate by examining the history of watershed development: how recreational uses were allowed, the court decision permitting the filtration waiver, and the regulatory and management impacts of this decision.

Finally, we see it as wise to “go beyond” our system and review how other filtered or unfiltered systems manage recreational activities.

This is just a rough outline. Once the study is completed, then an informed determination on the next steps could be made.
I would recommend to the MWRA that they share in the cost of this study with the State. I would further recommend that a representative of recreational activities have a seat on the working committee, along with DWSP, EOEEA, MWRA, and the Advisory Board. Together, their responsibility would be to flesh out the scope of the study and to evaluate the proposals, perhaps with varying perspectives, but equipped with the same facts. In return, I expect the public access rules to be respected and obeyed by all recreational users in the meanwhile.

Again, I stress that my job is to represent the interests of MWRA communities, and this means protecting our watersheds, ensuring our filtration waiver, and providing high quality drinking water to 2.5 million residents of Greater Boston.

I fully recognize that this issue is not limited to the most vocal debaters so far, but rather, affects many. In that spirit, the study ensures the most responsible path moving forward by providing all parties – myself included – with the knowledge to make the most educated decision possible. The stakes are enormous and allowing some fact-finding is the right next step.

Lead Service Line Replacement Collaborative

In addition to MWRA’s Lead Loan Program, the Lead Service Line Replacement (LSLR) Collaborative is an excellent resource for communities as they continue to rehabilitate critical water infrastructure. The site contains resources pertaining to all steps of the process:


  • A roadmap to build consensus with community stakeholders and to develop a plan for implementation
  • Tools for replacement practices, from highly technical descriptions to broader, more accessible language useful for outreach
  • Descriptions of policies
  • References to community case studies

The Collaborative was created to expedite voluntary LSLR in communities to keep lead out of drinking water and is composed of numerous national organizations. With topics as important as drinking water safety, the Advisory Board will to continue to equip our communities with the best tools available. Stay tuned for more updates!

New Challenges for MWRA Pellets

Our victory on establishing a science-based, defensible molybdenum limit, which would allow for the year-round, in-state, beneficial reuse of MWRA pellets, was thrown a curve ball by the recently released Department of Agricultural Resources Plant Nutrient Application Requirements for Agricultural Land Regulations 330 CMR 3.00.


In essence, the scope of the regulation has been dramatically increased, making it practically nonviable for land-use application of MWRA pellets in state.

In our comments, the Advisory Board states that “we laud DAR’s goal to regulate and enforce the registration and application of plant nutrients put on our soil to reduce phosphorus loadings to water bodies. However, all biosolids are not the same and need to be reviewed differently.” Click through to access MWRA and MWRA AB comments.

We will work closely with MWRA staff and DAR to ensure the in-state beneficial reuse of MWRA pellets are not only a goal, but also an attainable reality.