South Coastal Watershed Action Plan

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					                                 This project was funded by:

                           Massachusetts Executive Office
                                 of Environmental Affairs

      South Coastal Watershed
            Action Plan
 Executive Summary

Prepared by:

110 Winslow Cemetery Rd.
Marshfield, MA 02050
(781) 837--0982
                           The Commonwealth of Massachusetts
                                Executive Office of Environmental Affairs
                                          100 Cambridge Street
                                           Boston, MA 02114
     Mitt Romney

     Kerry Healey
LIEUTENANT GOVERNOR                                                                                   Tel: (617) 626-1000
                                                                                                      Fax: (617) 626-1181
  Stephen R Pritchard                                                                                   or (617) 626-1180

                                                        June 30, 2006

    Dear Friends of the South Coastal Watershed:

    It is with great pleasure that I present you with the 5-Year Watershed Action Plan for the South Coastal
    Watershed. This plan will be used to guide local, state, and federal environmental efforts within the
    watershed over the next five years. The plan expresses the concerns and potential actions to improve the
    environmental health of the watershed, such as improving water quality, restoring natural flows to rivers,
    protecting and restoring biodiversity and habitats, improving public access and balanced resource use,
    improving local capacity, and promoting a shared responsibility for watershed protection and

    The South Coastal Watershed Action Plan was developed with input from a diverse cross-section of
    stakeholders including watershed groups, state and federal agencies, municipal officials, Regional
    Planning Agencies and, of course, the general public from across the Watershed. We appreciate the time
    and energy so many gave to focus on the issues and challenges facing the watershed. From this input, we
    can better focus our efforts toward accomplishing the following priorities:

              •     Improve water quality by addressing point and non-point sources of pollution
              •     Protect and restore aquatic habitat
              •     Protect and Restore the natural hydrology
              •     Strengthen local capacity to protect and enjoy the South Coastal Watersheds

    I commend everyone involved in this endeavor. Thank you for your dedication and expertise. If you are
    not currently a participant, I strongly encourage you to become active in the watershed’s restoration and
    protection efforts.


                                                                Stephen R. Pritchard

This project was the collaboration of Jones River Watershed Association, North and South River
Watershed Association, Eel River Watershed Association, Pembroke Watershed Association and
Six Ponds Watershed Association with technical support from Lenehan Consulting. The time and
financial investment made on the part of these organizations was significant without which the
project could not have been completed. The support of state personnel in the Executive Office of
Environmental Affairs, the Department of Environmental Protection and particularly the noteworthy
contribution of George Zoto, former South Coastal Watershed Team Leader, was also critical to
our success. Lastly, warm thanks to the Steering Committee who tirelessly reviewed endless
drafts; to the many municipal employees who participated in phone interviews; and to the many
people who attended evening meeting and gave us their feedback.
                                    Executive Summary
                            South Coastal Watershed Action Plan
The watersheds of the South Shore Coastal
Basin are an important economic and ecological

asset to the nineteen communities of this 240
square mile region south of Boston (Figure E-1).
They include several independent coastal river
sub basins as well as significant groundwater            20  0   20  40 Miles

aquifer resources. More than 350 small coastal
plain lakes and ponds are scattered throughout
the basin, 14 of which are designated as Class A
Public Water Supplies and Outstanding Resource
Waters. Thirty two coastal plain ponds and streams, home to many endangered species are located
in the South Coastal basin and because they are fed by groundwater discharge they are
particularly sensitive to groundwater withdrawal impacts and contaminants. (Draft South Coastal
Pathogen TMDL, 2005).

The majority of municipalities rely on ground water wells for their public water supply (102 of the
                                                  108 permitted and registered water supplies in
                                                  the region are ground water wells). The most
                                                  significant groundwater resource is the
                                                  Plymouth/Carver sole source aquifer,
                                                  encompassing the southern portion of the South
                                                  Shore Coastal Watershed area. This aquifer, the
                                                  second largest in Massachusetts, underlies 140
                                                  square miles in eight towns in Southeastern
                                                  Massachusetts. It contains more than 500 billion
                                                  gallons of freshwater (on average), 168 million
                                                  gallons flow through the aquifer each day
                                                  (Hansen and Lapham 1992 and EPA 1990). EPA
                                                  designated it as a sole-source aquifer pursuant to
                                                  section 1424(e) of the Safe Drinking Water Act
                                                  since it provides much of the drinking water for
                                                  the region and, if groundwater contamination
                                                  were to occur, it would pose a significant public
                                                  health hazard and a serious financial burden to
                                                  the area residents (EPA 1990).

                                                   In general the aquifers of the region are located in
        Figure E-2 Plymouth Carver Aquifer         thin deposits of sand and gravel that cannot
sustain long-term large scale withdrawals (Metropolitan Area Planning Commission, November
2005). A distinct north/south differentiation exists in the characteristic of the basin’s surficial
geology. Overall, the surficial geology is mainly stratified-drift deposits (65%), or till and bedrock
(35%) However, thirty three percent of the northern 105 square miles (North and South Rivers

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       Subasins) is underlain by stratified drift deposits (the rest being bedrock and till), where 90% of the
       southern 135 miles is underlain by stratified drift (USGS, 2002). As a result of the very sandy soils
       often associated with stratified-drift deposits, pollutants including nutrients from cranberry bog
       operations, septic systems, lawn care, and stormwater runoff travel easily and quickly into the
       many pond, lakes, and shallow rivers. This addition of nutrients often results in algal blooms and
       excessive amounts of aquatic plants.

       The South Coastal Watersheds provide diverse and viable habitat for a rich diversity of flora and
       fauna including many rare and endangered species. Twenty percent of the South Coastal basin
       acreage is designated as Biocore habitat by the Natural Heritage and Endangered Species
       Program (purple areas in figure E-3). These areas are considered the most viable for sustaining a
       diversity of naturally occurring species. Fourteen percent of the basin’s acreage is designated as
       priority habitats of rare species and both habitat groupings are priority areas for protection.
       Plymouth, in particular, is a hot spot of biological diversity and is one of 5 areas in the state that
       has over 100 rare plants and animal records in the NHESP data base.

                                             The waterways of the South Coast have long been a core part of
                                             the culture in each community, offering historically important
                                             venues for commerce, fisheries (both inland and coastal), hydro
                                             power for grist mills, and boatbuilding trades. Mass
                                             transportation initiatives, starting with the Old Colony Railroad in
                                             1845, the building of Rt. 3 in 1959, the commuter rail in 1997 and
                                             now the extension of the Greenbush line to Scituate has and will
                                             continue to have profound impacts on the growth rate of the

                                             The region’s population and employment has grown significantly
                                             over the last ten years and is projected to increase by 16% and
                                             23% respectively by 2030. The largest population growth is
                                             anticipated in Weymouth (35%) and projected employment
                                             increases are anticipated for Kingston (1000-3000 new jobs) and
                                             Plymouth (greater than 3000 new jobs; MAPC unpublished data,
                                             January 2006).

                                           This growth has impacted and will continue to significantly impact
Figure E-3 NHESP Biocore Habitat in South  the natural resources of the region. Between the years 1971 and
             Coastal Basin                1999, the South Coastal basin lost 10.6% of its natural areas,
                                          representing 16,229 acres of mostly forest to mostly residential
         development. Marshfield has lost 500 acres of undeveloped land in three years (Town Planner
         Memo to Open Space Committee, March 2004), Plymouth is in the process of permitting a 1,000
         home development, and the development proposed for the South Weymouth Naval Air station
         Development will create 2,855 new homes and 1.5 million square feet of commercial space on
         1500 acres without an “in basin” water supply readily available. This project, located in the head
         waters of the North River Watershed is estimated, upon completion, to add 305 acres of
         impervious area, require 1.4 million gallons of water per day, and generate 1.3 million gallons per
         day of wastewater (Notice of Project Change, 2005). In Kingston, a new state zoning development
         (40R) under the “Smart Growth Initiative” is proposing 730 new homes in a mixed use transit
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oriented development, while the town is addressing at least four 40B proposals that would bring
over 200 new residences.

As impervious surfaces increase, water polluted by road and surface contaminates is rapidly
                                                      absorbed by surface waters instead of
                                                      naturally filtered and reabsorbed to recharge
                                                      groundwater aquifers. Large scale
                                                      development has meant the loss of
                                                      vegetated buffers and inadequate erosion
                                                      control. Related sediment and turbidity has
                                                      impacted anadromous fish spawning
                                                      habitat, eel grass communities, and the
                                                      overall natural functioning of ponds and

                                                          Many of the rivers, ponds and estuaries of
                                                          the South Coastal basin are already
                                                          stressed. Based on DEP’s 2006 Water
                                                          Quality Assessment, forty-nine percent of
                                                          the assessed rivers (25 river miles), and
                                                          39% (1638 acres) of assessed lakes no
                                                          longer support diverse aquatic communities.
                                                          A total of 17 lakes (1,314 acres) no longer
                                                          support diverse aquatic communities and
      Figure E-4 Shellfish Areas in South Coastal Basin   are impaired solely because of the presence
                                                         of non-native aquatic plants, most notably
fanwort (Cabomba caroliniana). Fifty-eight percent of the rivers (30 assessed river miles) are no
longer considered safe for primary recreational contact such as swimming and wading due to the
presence of bacteria, medals, and turbidity. Sixteen of the seventeen estuaries are impaired by
pathogens (Plymouth Bay in the only one not impaired) forcing the closure of 14,355 acres (11
percent) of the total south coastal shell fishing acres (Figure E-4). Based on this assessment,
thirty-six waterbodies are listed as impaired by pollutants in the Draft 2006 303(d) list of impaired
waters. Nine have been added since the 2002 list and 35 waterbodies or river segments in the
DEP database remain unassessed (DEP, 2006).

The Challenge
Six Watershed Associations, the Executive Office and Environmental Affairs, two Regional
Planning Agencies, the Office of Coastal Zone Management and over 130 citizens and municipal
representatives throughout the region participated in the development of this Action Plan to protect
and restore the important natural resources in the South Coastal Basin. The four goals of the
Action Plan are:
    1. Improve water quality by addressing point- and non-point pollutions sources.
    2. Protect and restore natural aquatic habitats.
    3. Maintain and restore the natural hydrology of watersheds.
    4. Strengthen local capacity to protect and enjoy watersheds.

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This plan outlines the necessary steps, some long-overdue, that residents, watershed associations,
businesses and state and municipal officials must take to manage sustainable growth. The action
plan calls for:
    •    Bylaw changes that will address stormwater impacts on estuaries and rivers.
    •    Water supply and waste water planning and management to be coordinated at the local
         level and in the context of what each watershed can sustain without damaging sensitive
         aquatic habitats.
    •    Fish passage to be restored and unnecessary obstruction and flow diversion be removed
         to restore the natural flow to our rivers and streams.
Lastly, the Action Plan outlines important steps that state, municipal and regional planning
representatives and watershed associations must take to effectively implement the proposed
changes as well as engage residents in the meaningful protection of our aquatic resources. These
steps are outlined for the South Coastal region as a whole, and more specifically in separate
chapters for six sub areas defined for the purposes of this action plan: the Gulf River and Scituate
Harbor Watersheds, the North River Watersheds, the Indian Head River Watersheds, the South
River and Green Harbor River Watersheds, the Jones River and Duxbury Bay Watersheds, and the
Plymouth Watersheds (Figure E-5).

The public process involved two steps, an assessment of South Coastal watersheds and the
development of a Five Year Action Plan. The assessment involved extensive literature review and
interviews with stakeholders. Based on this process, information and a list of recommended
actions were presented to the public for additional input and priority ranking. Their input and votes
defined the Five Year Action Plan. Each chapter of the South Coastal Action Plan consists of two
parts; The Assessment and the Five Year Action. The twelve members of the steering committee
played a crucial role in the guidance of this process (please refer to Appendix A for a detailed
description of the public process).

The Five Year Action Plan synthesizes the common issues that the region as a whole faces and
offers solutions that need local, regional, state, federal resources and talents. Without the
involvement of residents, businesses, watershed associations, state and local officials, and more
specifically those identified as “lead parties and funding sources,” the action steps outlined cannot
succeed. Together we can meet the challenge.

Goal 1: Improve water quality by addressing point and non-point sources of pollution.


The biggest cause of waterbody impairment in the state is pathogens and stormwater is an
important source of this pollutant in suburban areas. Stormwater run-off washes bacteria from a
wide range of sources into surface waters through stormwater systems or as overland flow directly
into surface waters. Pet and wildlife waste, illicit discharges to stormwater systems, and failing
private septic systems all contribute to high bacteria concentrations in stormwater. Sixteen of the
17 South Coastal estuaries have been significantly impacted by bacteria in stormwater. All the
south shore communities with embayments have been aggressive in obtaining grant and loan
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funds to implement stormwater control measures, to sewer areas that abut estuarine areas, and to
create shared upland septic systems. In addition, Plymouth, Duxbury, and Kingston have applied
to EPA for No Discharge Zone to be designated for 62 square miles of estuary. Yet, much work
needs to be done to continue to address existing stormwater sources impacting our estuaries,
rivers and ponds as well as prevent future sources as development continues. French Stream,
Drinkwater River, North River, South River, Iron Mine Brook, Jones River, Musquashcut Pond,
Second and Third Herring Brook, Forge Pond, Staley Pond are all known to be impacted by
pathogens and a TMDL is required (DEP, 2006).

All the South Coastal communities are subject to the Clean Water Act Phase II stormwater
requirements to set measurable goals for six control measures: public education, public
participation, illicit discharge detection and elimination, construction site run-off control, post
construction run-off control and pollution prevention/good housekeeping. All municipalities have
submitted a stormwater management plan and their efforts to date have primarily focused on the
significant task of mapping each municipal drainage system (for example, Hanover has over 3,000
catch basins and 1800 manholes), identifying illicit discharges and developing maintenance
systems. Some municipalities have begun to prioritize stormwater interventions, yet face the
expense and technical barriers of obtaining water quality data. Funding for water quality
assessment done in partnership with watershed associations will enable the prioritizing process.

Developing an on-going funding mechanism for the design and implementation of control
measures is needed for effective Phase II implementation. In 2004, a Massachusetts law was
changed to allow local communities to use taxes to raise revenue for developing and maintaining
stormwater systems. Chicopee is the only community in the Commonwealth to have established a
Stormwater Utility (ENSR, 2006). There is a need for more public education and municipal
technical support for the adoption of a model bylaw that was created in 2005 by Towns of Duxbury,
Plymouth and Marshfield (please refer to

Erosion and Sediment Control

         “The two biggest water quality issues are sedimentation and erosion from construction sites due to
         disturbed soil. I can’t tell you how many times we go to a wetland and find 2-8 inches of fine sand
         from a construction site. We have to look at a drainage map to discover what site it is coming from
         and if it falls within 200 feet of the river front I do monitoring and will shut down project if it affects
         even the buffer zone. But for projects that fall outside of the jurisdiction, even if the project has a
         NPDES permit, all I can do is suggest. Some of the worst impacts come from construction sites in
         which the conservation commission has no jurisdiction.”
                                      Michelle Simoneaux, Town of Norwell Conservation Officer.

The Clean Water Act Phase II requires towns to control pre- and post-construction stormwater run-
off via a NPDES permit for developments that are one or more acres. This Action Plan calls design
oversight for both pre and post construction drainage systems with on site enforcement by a
designated municipal employee or town approved contractor for all construction sites. As part of
this design review, consideration should be given to that fact that probably the most effective
means of reducing stormwater contributions to pathogen impairment is to reduce the volume of
runoff by increasing infiltration to groundwater. Low impact development approaches to
stormwater on the lot level result in a reduction in flushing of bacteria from contaminated surfaces
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and bacteria are removed from water that infiltrates though the soil matrix (ENSR, 2006).

Control of Road Salt and Other Contaminants

In each of the three public forums held during the assessment phase of this action plan,
participants gave long lists of specific road related impacts on South Coastal waterways.
Concerns about road salt contamination to wells in Hanover (Rt. 3), Marshfield (3A) and the
degradation that salt impacts and other road contaminants have on aquatic life in the Jones River,
tributaries to the Duxbury Bay (Rt. 27, Route 3 and 3A) and Plymouth ponds (Rt. 3) were noted.
The documentation required by the Massachusetts Highway Department regarding road salt
impacts focuses primarily on well water impacts and requires a year’s worth of monthly water
quality sampling before MHD commissioners vote (done annually) to designate a reduced salt
area (Farmington River Watershed Salt Impact Study, 2002). In addition, locally designated
reduced salt areas are, according to one official, difficult to implement because it requires
designating a truck just for that purpose.

Anti-ice experiments conducted in Canada, Minnesota and in Massachusetts (MHD,1995) found
that pre-wetting salt with Liquid Calcium Chloride (LLC) reduced the amount of material lost to run-
off and increased the effectiveness of salt by creating a brine solution which stops ice and snow
from forming. The costs savings of using LLC in Minnesota was $1.42 per two-lane mile
(Farmington River Watershed Salt Impact Study, 2002). Funding is needed for localities and MHD
to purchase saddle tanks to further pilot the applicability of LLC to Massachusetts highways and
local roads.

Priority actions for addressing point and non-point pollution are:
 1) Adopt the model storm water bylaw developed by the Towns of Duxbury, Marshfield and
Plymouth. Prioritize stormwater control measures based on the size of the watershed, the percent
of impervious surface, and its proximity to waterbodies. Include a program of water quality testing
to track progress and improvements. Develop a TMDL for pathogen impacted waters.
3) Develop a stormwater utility or alternative funding source to support on-going iterative
stormwater control measures.
4) Revise construction permitting to include drainage design review and on-site enforcement by
designated town official for all development and redevelopment projects.
5) Adopt guidance and specifications for de-icing controls along highways and major roads based
on impacts to sensitive receptors.

Goal 2: Protect and Restore Aquatic Habitats

The impacts of pollutants and nutrients are exacerbated by the diversions of river flow. In the
South Coastal watersheds diversions are caused by public water supply needs, the operation of
3,327 acres of cranberry bogs, 147 dams and multiple tidal marsh restrictions. These flow
impediments prevent fish passage, trap nutrients, create flooding conditions, increase water
temperatures (already warmed by impervious surfaces) and create favorable growing conditions for
invasive species and algae. Furnace Pond, located in the North River Watershed, is a poster-pond

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example of how high nutrient levels caused by stormwater run-off, non-functioning fish passage,
high water temperatures due to reduced flow and water diversions can cause the near death of a

Impacts of Dams

The 147 dams in the South Coastal basin are located along tributaries and are for the most part,
vestiges from our early mill industries. In many cases, these dams are privately owned, relatively
small and literally disintegrating. While most of these dams would not pose a significant public
health hazard if they were suddenly to break, each one has an impact on our public resources,
fragmenting river habitat, isolating fish populations, diminishing biological diversity, preventing
coastal fish from spawning their historical breeding grounds, altering stream flow and preventing
sediment from flowing downstream to feed marshes that mitigate for flooding. Because dams trap
                                                       sediments in their impoundments there may
                                                       also be concerns over the contamination of that
                                                       sediment and if one of these antiquated dams
                                                       were to break, the release of potentially
                                                       contaminated sediment could have disastrous
                                                       effects on downstream habitats or water

                                                          The Dam Safety Report (May, 2006), issued by
                                                          the Dam Oversight Committee in response to
                                                          the Taunton’s Whittenton Dam crisis
                                                          recommends that a low interest revolving loan
                                                          fund be established and used by owners for the
                                                          dismantling of dams that are expensive to
                                                          maintain and no longer serve any functional
                                                          public purpose. It is a priority of this action
                                                          plan that local communities take the lead in
                                                          inventorying dams to identify flooding issues,
                                                          prioritize dams for removal, and to solicit and
                                                          support the owners during the permitting
    Figure E-6 Massachusetts Riverways Inventory of
              Dams in South Coastal Basin
                                                          Anadromous Fish

Herring runs have long been part of the cultural heritage of the South Coastal watersheds and
several communities have over recent years taken steps to restore fish passage to promising
herring runs. Efforts include the removal of the Town Brook dam in Plymouth, improvements to the
fish passage devices at Hunter Brook (Cohasset), and an assessment of Wapping Road, Forge
Pond and Stony Brook dams on Jones River (Kingston) and the restoration efforts of the Island
Creek run in Duxbury. The Division of Marine Fisheries TR-17 report lists 31 potential herring runs.
A priority of this action plan is for local communities to build on Department of Marine Fisheries
efforts by developing a fish restoration program that assesses, designs and implements restoration
plans for prioritized sites. Part of this effort will include an “Adopt of Fish Run” initiative that
engages the broader public in its implementation.
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Impacts of Cranberry bogs

Impacts of cranberry bogs on both water quality and a water flow are significant. Eighteen ponds
and rivers on the draft 2006 integrated list of impaired waters are hydrologically or hydraulically
connected to cranberry bogs and potentially impacted by nutrients. Cranberry bogs reduce and
manipulate flow direction resulting in higher water temperatures and rendering it nearly impossible
for anadromous fish to make passage to spawning grounds. It is important that farm plans and
management guidance be developed and implemented that will minimize agricultural impacts to
water quality, water flow, and improve aquatic habitats. Agriculture Commissions could play an
important role in this effort by obtaining technical assistance on conservation farm planning,
nutrient management, environmental stewardship, and non-point source pollution (MA Department
of Agricultural Resources, June 2005).

Impacts of Aquatic Invasive Species

Seventeen of the DEP assessed waterbodies are impaired by invasive species. The most notable
freshwater species are Cabomba Caroliniana (Fanwort) and Myriophyllum heterophyllum (Variable
milfoil). These aquatic macrophytes propagate through seed dispersal and fragmentation and can
easily dominate an entire pond rendering it unusable for recreational purposes. In addition, dense
plant growth, in combination with nutrient laden waters, accelerates the eutrophication of a pond.
Furnace Pond, for example is significantly impacted with curley leaved pond weed and fanwort,
purple loosestrife and phragmites. Water lilies clog many areas of the Pond, rendering any
recreational activities nearly impossible. The condition of Furnace Pond impacts not only Silver
Lake (the pond is a water supply for Brockton), but may also soon spread to include Herring Brook,
and eventually the North River.

Existing control efforts in Massachusetts are conducted largely through local initiatives, many of
which receive support fro the Lakes and Ponds Program. Improved detection and rapid response
to new invasions and additional public education are priority actions for the effective management
of aquatic invasive plant species. Another species of concern, Phragmites australis, is invasive of
both fresh and saline marshes, and forms dense monocultures that displace native vegetation
thereby reducing the habitat value of wetland systems. Removal is by mechanical harvesting,
application of herbicides, or restoration of natural hydrology, all difficult and costly (MA Aquatic
Invasive Species Plan, December 2002). Strategies to manage and control the spread of invasive
species and restore native species need to be developed. To help in this process, invasive
species that pose a threat to native species need to be identified and mapped. Concern is rising
regarding the emerging prevalence of green and Asian crabs in estuaries and near coastal waters.

Protecting Priority Habitats

The Action Plan highlights the protection and restoration of aquatic habitats by prioritizing the
acquisition of land adjacent to waterways, enforcing no-build set-backs as defined by local
ordinances, the Wetland Protection Act and the Rivers Protection Act, and promoting the
development of local zoning ordinances such as Transfer Development Rights to protect NHESP
priority habitats. The Rivers Protection Act protects a 200 foot buffer for rivers and perennial
streams. As development pressures increase, the definition of what constitutes a perennial stream
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becomes paramount to site plan review. Initial designation of a stream being perennial or
intermittent at a site is determined by the most current USGS topographical map, which may or
may not accurately represent a perennial or intermittent status. The regulations, however, do allow
the reversal of the perennial or intermittent status at a stream site if a competent source can
provide specific evidence to the contrary. To assist city and town conservation commissions and
the MADEP in determining whether a stream is perennial or intermittent at a site, a logistic
regression equation was developed by the USGS in cooperation with EOEA. This method
provides an objective means for estimating the probability of a stream flowing perennially at
specific sites that have the characteristics for which the data is proven reliable (USGA, 2002). In
order to maximize the applicability of the Rivers Protection Act, this action plan recommends that
DEP provide technical assistance to conservation commissions to update definitions of perennial
and intermittent status of streams and devise methods to publish findings and update maps as
perennial streams are determined through public hearing processes.

Tidal Wetlands

Tidal Wetlands are among Massachusetts’ most valuable natural resources. Often called the
ocean’s farmlands, these wetland systems create the foundation of a coastal food web that
supports a large variety of coastal fish and bird species. Tidal restrictions (culverts, tide gates)
cause hydrologic changes that typically reduce the maximum elevation of tidal flooding and lower
the water’s salt concentration. These changes cause a major transformation in vegetation and
alter the entire upstream salt marsh. MAPC and the Massachusetts Wetland Restoration Program
assessed sites throughout the South Coastal Basin and after considering several factors they
identified twelve South Coastal high priority sites for restoration (MAPC, 2001). This action plan
prioritizes six of these sites for restoration over the next five years: Green Harbor (Marshfield),
Musquashcut Pond (Scituate), Treats Pond (Cohasset), Tussock & Stony Brook (Duxbury &
Kingston), James Brook (Cohasset), and Bluefish River (Duxbury). Restoration of these tidal
wetlands may also help to address bacterial pollution by the reintroduction of tidal exchange.

Priority Actions for Protecting and Restoring Aquatic Habitats are:

    1) Create town committees (inter-town when necessary) to inventory all flow impediments
       (impoundments, culverts, cranberry bogs and PWS diversions), identify flooding issues,
       prioritize dams for removal, and support owners in the permitting process for flow
       impediment removal.
    2) Develop a fish restoration program in each community that assesses, designs and
       implements restoration plans for prioritized sites. Part of this effort will include an “Adopt a
       Fish Run” initiative that engages the broader public in its implementation.
    3) Develop a strategy to manage and/or control the spread of invasive species and restore
       native species. Map and identify invasive plants & aquatic animals that pose a threat to
       native species.
    4) Protect and restore aquatic habitats by acquiring land adjacent to waterways, updating
       perennial stream designations, enforcing protective set-backs as defined by local
       ordinances, the Wetland Protection Act and the Rivers Protection Act. Promote the
       development of local zoning ordinances to protect NHESP priority habitat such as Transfer
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         Development Rights and require habitat assessment studies prior to permitting projects
         located in priority habitats.
    5) Restore tidal wetlands by removing restrictions or using the most appropriate methodology
       determined by adaptive management restoration efforts.
    6) Implement farm plans with management guidelines for cranberry bogs that will minimize
       agricultural impacts to water quality and aquatic habitats including pest control.

Goal 3: Protect and Restore the Natural Hydrology of our Watersheds

Understanding the impact that water supply withdrawals and the unnatural displacement of water
via stormwater and wastewater systems has on the natural hydrology of our watersheds and their
aquatic habitats is imperative. Generally, it is not sustainable to withdraw water from one location,
use it at a second location, and discharge it to a third while throwing away rainfall as polluted
stormwater (Zimmerman, May 2006). More specifically, the impacts of flow diversion and water
withdrawal for potable water, wastewater, cranberry bog operation and irrigation purposes on the
sustainable functioning South Coastal rivers and steams need to be better understood and
incorporated into stream and aquifer management plans, cranberry bog operation plans, municipal
water supply decisions and considered in the issuance of Water Management Act permits.

Six communities have initiated the permitting process for new wells (Duxbury, Plymouth, Kingston,
Marshfield, Pembroke, and Norwell) four communities have exceeded the WMA withdrawal limits
based on MAPC data of average daily demand for 1998-2002, (Cohasset, Scituate, Hanover, and
Pembroke ) and three more are projected to do so by 2030 (Hanson, Abington/Rockland,
Weymouth). Based on MAPC four year baseline ADD data, South Coastal Communities withdrew
a total of 25.2 MGD annually, representing 71% of the total WMA withdrawal limit for the region.
Almost 14 MGD are supplied by surface waters of which 10 MGD come from Silver Lake, the most
significant surface water source in South Coastal.

Cohasset, Scituate, Marshfield and Plymouth have recently or are expecting to expand or increase
the capacity of their wastewater systems that discharge water into or adjacent to the ocean and
reduces the amount of water recharging the aquifer. As water suppliers rightly adjust pricing of
water according to increased usage, households are turning to private well sources for irrigation.
Marshfield, a community of approximately 8,000 homes has nearly 400 registered wells. The
overall impacts of these withdrawals are unknown and calls for an evaluation of the hydrolic
balance of specific watersheds. Projected water deficits can be changed and the impact of water
withdrawals on the hydrolic balance of watersheds can be reduced with management actions that
focus on conservation, peak seasonal demand reduction, water reuse/recycling, stormwater
recharge and public education.

As demand for water increase, towns continue to take steps to protect land in key aquifer recharge
areas. Of particular concern is the lack of protection for the Plymouth Carver Aquifer, the primary
public water supply for seven south coastal communities. A recent study done by Wright and Pearce,
indicated a two-fold increase in water withdrawals from the PCA since 1985, and a USGS study is
underway to develop and apply a new ground-water-flow model of the region to evaluate the effects
of the future ground water withdrawals, and the impacts of seasonal variation in pumping and aquifer
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recharge. The flow model will be used to delineate areas contributing recharge to supply wells,
streams, selected ponds and coastal resources, and will be used to develop water budgets and
withdrawal tolerance levels for each watershed based on groundwater boundaries. Study results
must be incorporated into memorandums of agreement between the seven communities utilizing this
resource to insure sustainable utilization of this resource.

Several watershed systems are exhibiting flow-related stress. One of the most notable is the
Jones River. Due to diversion of 10 million gallons per day (from the south coastal Jones River
basin to the Taunton River basin) related to Brockton’s water supply needs, the river experiences
zero flow in “normal” precipitation years from June to the following January. In dry years such as
2000-2002, this no flow condition lasted 23 months. A GZA modeling effort describes under
natural conditions flow from Silver Lake would range from a low of 7cfs to 40cfs. The WMA
permit in this case requires Brockton to complete a comprehensive water management plan that
ensures a level of continual flow to the Jones River to sustain healthy riverine habitats. If done
correctly this plan could be a model for managing other flow-related impacts. Other streams
impacted by the Brockton management include Furnace Brook and Herring Brook in the North
River system and Stump Brook in the Taunton River system. Besides impacting flows
downstream, the dams required by the diversion systems and the amount of water withdrawn to
Silver Lake exacerbates the excessively poor water quality in the source water pond(Furnace and
Oldham Ponds and Monponsett Ponds), which has led to diminished water quality, and especially
high phosphorus levels in Silver Lake.

In the North River Watershed potential impacts of public water supply demands on First Herring
Brook (a diversion) and Third Herring Brook (multiple withdrawals) needs to be evaluated.
Watershed budgets for each Brook needs to be developed in which habitat needs, water supply
capacity availability and water management actions to protect stream flow are defined and

Water Budgets

EOEA is currently engaged in a state-wide water budget study that lends itself to a joint state/local
effort. The EOEA study will assess the current and potential water supply capacity and the current
and potential water demands in communities throughout the commonwealth. The assessment is
intended to provide a framework for long-term public water supply planning and protection of
essential ecosystems. Further the impact to groundwater, streams and watersheds of moving
water, primarily via pubic drinking water and wastewater systems, in and out of watersheds and
subwatersheds (tributary basins) also will be evaluated. The result sought is an assessment of
where there are subwatersheds out of balance in hydrological and environmental terms (email
correspondence, John Clarkeson, EOEA 4/13/2006).

WMA Permits

Currently most of the authorized water withdrawals in South Coastal are registered withdrawals
(84) with 19 are permitted withdrawals (only three with performance standards; personal email Jan
Drake, DEP March 13, 2006). Five year reviews for each WMA permit in the South Coastal are
scheduled for FY 06 and FY07 during which conservation performance standards will be
incorporated into all permits. The conservation standards for medium and high stressed basin
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require 65 residential gallons per capita per day (rgpcd ), 10% unaccounted for water (as a
percentage of overall water), include summer withdrawal limits, and require offset feasibility studies
for water withdrawals that exceed baseline withdrawal volumes. Because the State has yet to
determined the stress level of the South Coastal basin, the conservation standards are less
stringent, (85% rgpcd and 15% unaccounted for water), with no summer withdrawal limit or offset
feasibility studies when withdrawal amounts are exceeded (WMA Guidance Policy, 2006). The
State is in the process of significantly improving the methodology used in determining river and
stream stress levels that takes into account impacts of flow on river biology and habitats. The
State anticipates applying this methodology statewide in 2007 and incorporating the results into
water withdrawal permitting decisions to better insure the sustainable use of our water resources, a
goal articulated, but not yet achieved by the 1986 Water Management Act. .

All WMA withdrawal registrants (84 permits in South Coastal) state-wide will expire on January
2008. The reauthorization of these withdrawals presents an opportunity for watershed
associations, municipalities, EOEA and DEP to introduce relevant data pertaining to the hydraulic
balance and environmentally sustainable withdrawal levels of watersheds into the WMA
registration process. Such an effort begins to address unsustainable withdrawal limits that in some
areas have caused species and habitat destruction. Incorporation of water budgets and definitions
of sustainable yields made in the context of river ecological health will introduce a precautionary
principle to water resource management as communities grapple with obtaining enough potable
water to meet their needs.

Recycling Water

There are many benefits of recycling water applicable to the South Coastal Watersheds. Water
reuse provides an increment of supply for growing communities, reduces or eliminates treated
wastewater discharges into sensitive waters, decreases the diversion of freshwater from sensitive
ecosystems, provides a mechanism for wetlands and aquifer recharge and reduces the need to
transport water from expensive distant water suppliers. Most of the water reuse applications
allowed in Massachusetts are for commercial water reuse including irrigation of golf courses,
landscaping, recharging zone II aquifers in distressed areas or areas with low stream flow, and
toilet flushing in commercial properties (Interim Guidelines 2000). Effluent treated to the tertiary
level can be used for groundwater recharge in stressed river basins, although current groundwater
laws may present liability issues for the water supplier (MAPC, November 2005).

DEP has permitted a handful of commercial projects across the state on a case-by-case basis
including Gillette Stadium, Wrentham Premium Mall, Bayberry Hills Golf Course in Yarmouth and
Indian Pond Estates, in the South Coastal community of Kingston. Kingston, faced with constraints
for subsurface disposal, chose to use part of the treated effluent for irrigation at the proposed golf
course with the rest going to a leaching field that helps recharge the aquifer. As of this writing, the
effluent reuse plan has yet to be implemented (Conversation with Pine duBois, JRWA 2006).

Reducing Water Withdrawal for Irrigation

It is anticipated that DEP will issue during the summer of 2006 draft guidelines that will include the
use of reclaimed water for irrigation on fields, playgrounds and ballparks. The town of Plymouth is
seeking to recycle/reuse wastewater from their WWTP within the Eel River Watershed to irrigate
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golf courses and recreational fields and is seeking funding from EPA to cover the costs of
additional infiltration and disinfection and the construction of groundwater recover wells
downstream of the infiltration basin. It is estimated that 150 million gallons a day of recycled
water would be redirected to these fields thereby recharging the aquifer and reducing the nitrogen
discharged annually into the infiltration beds at the Town's Camelot Park WTTP (located adjacent
to the Eel River) by forty-five percent (Plymouth’s funding application to EPA). The opportunity for
irrigation reuse exists in Cohasset as well. The upgraded facility has the capacity of .78MGD and
the Town of Cohasset wants to increase their permitted amount by 30% to 0.4 MGD. Given the
sensitivity of the Cohasset Cove to fresh water discharge and nitrogen loading, effluent reuse
should be reconsidered in the permitting process (Jason Burtner, personal conversation, April

The rate of water consumption in the summer in suburban communities increases dramatically due
to irrigation demands. A Seattle study found that suburban properties consume nearly 16 times
more water than traditional urban houses with smaller lawns (New England Public Policy Center,
2005). EPA estimates one third of all water used by households occupying such large homes is
devoted to outdoor activities such as law and garden watering (Otto, et al. 2002 in NEPPC, 2005).
The common misconception that most of the applied water percolates through the soil and
recharges the groundwater is completely false. Depending on the irrigation system, 50-75% of the
applied water is lost to the atmosphere (Zimmerman, May 2006).

A closer look at the seasonal water cycle underscores the impact that increased summer demands
has on watersheds. In Massachusetts, the average annual precipitation is about 45 inches. Under
natural conditions in a watershed, about 22 inches per year evaporates, another 5 inches per year
is lost to runoff, leaving 18 inches of water to recharge the groundwater. In the summer months
however, there is little runoff, and only about .5 inches of the 3.8 inches per month of precipitation
is recharged. During dry summer months there is almost no recharge and streamflow and
recharge are in a delicate balance. In areas with high demand, this balance is offset by water
withdrawals causing stream draw down, increased water temperatures, and concentrated pollution
(Zimmerman, 2006). Water usage increases in South Coastal communities, notable in Norwell,
Marshfield, and Plymouth nearly doubles in the summer. This action plan calls for the
development of landscaping bylaws that will define development guidelines for irrigation systems
with soil moisture sensors, limiting the size of lawns in new development and encouraging the use
of indigenous plants with less intensive water needs.

Priority Actions for Restoring and Protecting the Natural Hydrology of our Watersheds are:

    1) Develop water budgets for subwatersheds in which habitat needs, water supply capacity
       availability and water management actions are defined and implemented to protect stream
    2) Develop locally integrated waste water, water supply and stormwater management plans
       based on subwatershed budgets and incorporate such budgets into the WMA and DEP
       permitting decisions. The integrated water conservation plans will define measures to
       reduce inflow and infiltration and maximize stormwater recharge.
    3) Define the sustainable yield for the Plymouth Carver Aquifer and implement a water use
       and recharge budget for each community accordingly.
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    4) Evaluate feasibility of recycling WWTP effluent for irrigation purposes in development and
       redevelopment projects and for the irrigation of community golf courses and recreation
       fields in each South Coastal community.
    5) Implement Landscaping Bylaws that promote the conservative use of water by defining
       guidelines for irrigations systems with soil moisture sensors, limiting the size of lawns for
       developers, and encouraging the use of indigenous plants with less intensive water needs.
Goal 4: Strengthen local capacity to protect and enjoy South Coastal Watersheds.
         “First thing we need to do is spend ten times more on education. Knock on doors in the summer
         time, expand the Greenscapes program. Every person needs to understand the water issues in
         the community.” Steve Ivas, Norwell Water Commissioner
Recommended actions for this goal focus on the engagement and integration of stewardship
efforts at the local, regional, and state levels that include the development of regionally consistent
“smart-growth” bylaws, stronger enforcement of existing and to be developed environmental laws
and ordinances, and greater use of the media to educate and encourage stewardship practices.
These priorities reflect the recommendations by the Massachusetts Ocean Management Task
Force in its 2004 “Making Waves” report calling for “federal/state/regional cooperative ecosystem
management”; a higher priority placed on “enforcement of our existing environmental laws”
protecting our ocean and coastal resources; and a commitment to “developing a new ocean (and
coastal) literacy and stewardship ethic among all citizens of Massachusetts (CZM, 2004).
Development pressures and increases in population are with increasing frequency placing human
uses of water resources at odds with ecologically sensitive and invaluable habitat. Often impacts
originating in one municipality significantly impact habitat in a neighboring municipality and towns
are turning to each other in partnership to develop effective solutions. For example, the towns of
Kingston, Plymouth and Duxbury hope to create a regional resource management plan for the Bay
that will potentially identify and protect sensitive ecological areas and create “use zones” as
necessary. Any proposed solution however needs state leadership, the commitment of
resources, public education, and enforcement to be effective. Accordingly, the priority actions for
this goal are:
1) Develop regionally consistent smart growth bylaws and regulations by town that focus on water
   protection measures inclusive of stormwater bylaws, stormwater utilities, low impact
   development bylaws, landscaping bylaws, and integrated water conservation plans. South
   Coastal Regional Planning agencies, in a coordinated application, will seek funding from Smart
   Growth Technical Assistance Grants, 604(b) funds, and private foundations to implement a
   state sponsored Circuit Rider program that will involve all town boards in the development of
   new bylaws (including fire departments, homeland security, police departments).
2) Strengthen state and federal leadership by engaging state and federal elected officials in
   watershed activities, as well as politically connected advocacy groups.
3) Increase town capacity to implement applicable actions of this plan by hiring a CPA planner
   with CPA administrative funds. Also encourage communities to use chapter 53(h) of
   Massachusetts General Law to require developers to fund an independent review of proposed

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4) Improve public education efforts by targeting the message to the region’s demographics and
   utilizing cable access TV to educate viewers regarding water conservation, lawn chemical
   applications, aquifer protection and wetlands/watershed ecology.
5) Develop and implement in-school and after-school “hands-on” watershed curriculum.
In conclusion, this Action Plan defines a road map for the protection and restoration of our aquatic
resources over the next five years. It reflects the many voices of residents, watershed
associations, town, regional, and state officials who have tirelessly devoted themselves to the
articulation of this vision. It provides a snapshot of what is known about the current conditions of
our water resources and general guidance for additional data and monitoring. As new data are
compiled, the plan provides a framework for the formulation of additional actions that will maximize
watershed protection and restoration. With leadership by all, and with the commitment of state,
federal and municipal financial resources, these actions, once implemented, will make a difference
in the long-term health of our watersheds.

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South Coastal Watersheds Five Year Action Plan
                              Priority Actions                                      Lead parties                Funding sources          Calendar Years
                              South Coastal                                                                                              1   2   3   4   5
Goal #1 Improve Water Quality by addressing point and non-point sources of pollution
Proposed Actions for the next five years:
1.1 Adopt model stormwater bylaw developed by Marshfield, Duxbury
                                                                                                         EOEA Smart Growth TA Grants,
and Plymouth in 2005. Prioritize stormwater remediation based on size of    Municipalities, Riverways,
                                                                                                         Riverways, Lakes and Ponds
watershed, the percent of impervious surface and proximity to               DEP, Regional Planning
                                                                                                         Program, 604(b) Water Quality
waterbodies. Include a program of water quality testing to track            Agencies Watershed
                                                                                                         Planning Grants, Coastal
progress and improvements. Develop a TMDL for pathogen impacted             Associations
                                                                                                         Pollution Remediation Grants
303(d) list waters.
1.2 Revise construction control permitting to include drainage design       Muncipal Planning Boards,
review and on-site enforcment by a designated municipal official for all    Conservation Commissions, Municipal funds for enforcement
development and redevelopment projects.                                     Buidling Inspectors
1.3 Develop a Storm Water Utility or some means to fund on-going
                                                                            Municipalities               Smart Growth TA Grants
stormwater remediation efforts.
1.4 Adopt guidance and specification for de-icing controls along highways
                                                                            DEP, MHD, Municipal      State Revolving Fund, Section
based on impacts to sensitive receptors. Fund Pilot programs for Liquid
                                                                            Public Works Departments 319 Grants
Calcium Chloride.
1.5 Support passage of the federally approved boat sewage No                Towns of Plymouth,
Discharge Area for the Plymouth/Kingston/Duxbury Bay                        Kingston, Duxbury, EPA
Goal #2 Protect and Restore Natural Aquatic Habitats
Proposed Actions for the next five years
                                                                            ConComms, Watershed
2.1 Create town committees (inter-town when needed) to inventory all
                                                                            Associations, DEP, Office    Watershed Imrovement Grants,
flow impediments (impoundments, culvert, cranberry bog and PWS
                                                                            of Dam Safety, Board of      Army Corps of Engineers (Sec
diversions), identify flooding issues, prioritize dams for removal, and
                                                                            Selectment, MEMA,            22)
support owners in the permitting process for flow impediment removal.
                                                                            Riverways, AgComms

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                              Priority Actions                                      Lead parties                 Funding sources          Calendar Years
                              South Coastal                                                                                               1   2   3   4   5
                                                                                                         CPA, Land Trusts, Self Help
2.2 Protect and restore aquatic habitats by acquiring land adjacent to
                                                                             Water Suppliers, Land       Grants, Drinking Water Supply
waterways or in aquifer protection districts. Enforce protective set-backs
                                                                             Trusts, CPA Committees,     Protection Grants, DFG Land
as defined by local ordinances, the WPA, and the RPA. Update
                                                                             ConComms, Planning          Protection Program, CZM/NOAA-
intermittent stream designations, and promote local zoning ordinances to
                                                                             Boards, DEP, Dept of Fish   habitat assessemnts. Municipal
protect NHESP habitats by requiring a natural resource assessement
                                                                             and Game, Developers        funds for enforcement,
prior to permitting.
2.3 Develop a plan to manage/control spread of invasive species and
restore native species. Map and identify invasive plants that pose a threat CZM, Mass Bays Program       CZM, MIT Sea Grant Program
to native species.
2.4 Develop a fish restoration program in each community that assesses,      Watershed Associations,
                                                                                                       MA Environmental Trusts Grants,
designs, and implements restoration plans for prioritized sites. Part of     Conservation Commissions,
                                                                                                       Watershed Improvement Grants,
this effort will include "Adopt a Fish Run" initiative that engages the      Riverways, Mass Bays
                                                                                                       NOAA, Gulf of Maine Council
broader public in its implementation.                                        Program
2.5 Restore tidal wetlands by removing restrictions or using the most
appropriate methodology determined by adaptive management                    Municipalities, CZM, MAPC Wetlands Restoration Program
restoration efforts.
2.6 Implement farm plans with management guidance for bogs that will
                                                                             Agriculture Commissions,
minimize agricultural impacts to water quality and aquatic habitats                                      New Tax Incetives
                                                                             Watershed Associations
including pesticide control.
Goal #3 Maintain and Restore the Natural Hydrology of Watersheds
Proposed Actions for next five years
3.1 Develop water budgets by subwatershed in which habitat needs,            Water Suppliers,
water supply capacity availability and water management actions are          Watershed Associations,
                                                                                                         Watershed Improvement Grants
defined and implemented to protect stream flow and sustainability of         Riverways, USGS, EOEA,
watershed.                                                                   WRC, DEP
3.2 Develop locally integrated waste water, water supply and stormwater      DEP, Water Suppliers,
plans based on subwatershed budgets and incorporate such budgets into        Watershed Associations,
                                                                                                         Smart Growth TA Grants
the WMA and DEP permitting decisions. The plans will define measures         Riverways, Regional
to reduce I/I and maximize stormwater recharge.                              Planning Agencies

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                              Priority Actions                                        Lead parties                 Funding sources         Calendar Years
                              South Coastal                                                                                                1   2   3   4   5

3.3 Implement landscaping bylaws that promote the conservative use of         DEP, Municipalities,
water by defining guidelines for irrigation systems with soil moisture        Regional Planning
                                                                                                          Smart Growth TA Grants
sensors, limiting size of lawns in new developments, and encouraging the      Agencies, Watershed
use of indigenous plants with less intensive water needs.                     Associations
3.4 Use the currently funded USGA study to define the sustainable yield       USGS, DEP, Regional
for Plymouth Carver Aquifer, define groundwater boundaries for PCA            Planning Agencies,
                                                                                                          Already Funded; Study underway
watersheds, and implement a recharge budget for each community                Watershed Associations,
accordingly.                                                                  Municipalities
3.5 Evaluate feasibility of recycling WWTP effluent for irrigation purposes
                                                                              Municipal Planning Boards,
in development and redevelpment projects and for the irrigation of
                                                                              DPWs, BOH, DEP,            Watershed Improvement Grants
community golf courses and recreation fields in each South Coastal
                                                                              Regional Planning Agencies
Goal #4 Strengthen local capacity to protect and enjoy watersheds
Proposed Actions for next five years

                                                                              Regional Planning Agencies
4.1 Develop regionally consistent smart growth bylaws and regulations
                                                                              to write regional grant for
by town that focus on water protection measures inclusive of stormwater
                                                                              state agency budget (CZM) Smart Growth TA Grants, 604(b)
bylaws, stormwater utilities, low impact development bylaws, landscaping
                                                                              to fund circuit riders. All grants, Private Foundations
bylaws, integrated water conservation plans. Provide circuit rider for
                                                                              municipal boards (including
technical assistance, and target municipal funds for bylaw enforcement.
                                                                              fire dept.).
                                                                         Governor, EOEA, State
4.2 Strengthen state leadership on watershed protection measures by
                                                                         Representatives and
engaging Federal and State elected officials and advocacy/user groups in                          Watershed Improvement Grants
                                                                         Senators, WRC, Watershed
watershed activities.
                                                                              Local Schools, Jones River
                                                                                                          Gulf of Maine Council, MA
4.3 Develop and Implement in-school and after-school programming for          Landing, Duxbury Bay
                                                                                                          Environmental Trust, Private
hands-on watershed curriculum.                                                Maritime School, Center for
                                                                              Student Coastal Research

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                           Priority Actions                                   Lead parties                    Funding sources       Calendar Years
                       Duxbury Bay Watersheds                                                                                       1 2 3 4 5
4.4 Continue regional "Greenscapes" education on landscaping practices Watershed Associations,
                                                                                                       Water Suppliers
that protect water.                                                    Water Suppliers
4.5 Increase town capacity to implement applicable actions of this plan by
hiring CPA planner with CPA administrative funds. Also encourage           Municipal Planning Boards
                                                                                                       Community Preservation Act
communities to use Massachusetts General Law Chapter 53(h) that            and Boards of Selectmen
requires developers to fund an independent review of proposed projects.
4.6 Improve public education efforts on cable TV Access by targeting
                                                                         JRWA, Towns of Kingston
message to region's demographic regarding water conservation, lawn
                                                                         and Duxbury, Duxbury Bay Watershed Improvement Grants
chemical applications, aquifer protection, and wetlands/watershed
                                                                         Management Committee

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      Figure E-1 South Coastal Communities

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    Figure E-5 Sub-Watersheds of the South Coastal

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