Protecting our environment
The idea of environmental protection has taken many forms. Native Americans speak of considering the needs of many generations
to come. When organic method growers deal with pests they look for methods which minimize effects on non-target organisms.
When our state government looks at pest management, such thoughtfulness seems to be lacking. We're trying to convince them
to take the long view instead of a quick fix approach.
2006 Letter from the Natick Board of Health to the Natick ConCom
OFFICE OF THE
Board of Health
13 EAST CENTRAL STREET
NATICK MASSACHUSETTS 01760
April 19, 2006
Natick Conservation Commission
13 East Central Street
Natick, MA 01760
Re: Lake Cochituate Aquatic Plant Management Program
Attention: Matthew Gardner, Ph.D, Chairman
Dear Dr. Gardner:
In January of this year the Board of Health was advised by Mike Gildesgame, Mass. DCR, that DCR would be filing two Notices
of Intent for the treatment of invasive nuisance weeds in Lake Cochituate. Mr. Gildesgame said he anticipated that the Conservation
Commission would likely request an opinion or recommendation from the Board of Health concerning the portion of these NOI's
that included the use of chemical herbicides in the lake.
The Board of Health requested that DCR engage an independent consultant, to be selected from a list of qualified consultants
submitted by the Board, to provide the Board with expert technical advice in this matter. The consultant was to be expert
in water chemistry and the fate and transport of chemicals in the environment, and was not to be employed by the lake treatment
or chemical herbicide industries.
Ultimately the State engaged Warren J. Lyman, Ph.D from the Board's list list. Dr. Lyman submitted a report which the Board
received electronically on March 7, 2006. A copy of Dr. Lyman's report, dated MaRCH 7, 2006, is attached.
The Board held a public hearing on this matter on March 27, 2006. Dr. Lyman was in attendance at this public hearing where
he gave an overview of his report and responded to questions from Board members and from the public.
Prior to the March 27th public hearing, the Board had received written materials, including some from DCR and some from interested
citizens, several of whom also addressed the Board, at their earlier meeting of February 27th.
At the conclusion of their March 27th hearing, having reviewed all of the material submitted, the Board of Health voted unanimously
to recommend against the use of chemical herbicides, especially fluridone, in Lake Cochituate as proposed in the NOI's for
the following reasons:
1. According to Dr. Lyman's report, and also according to the report from the Mass. DEP Office of Research and Standards which
was submitted by DCR, it is "almost a certainty" that if fluridone is used in the lake it will enter the groundwater and be
present in the Town drinking water wells at the Springvale site.
2. Although fluridone is approved by the EPA for use in drinking water supplies for controlling aquatic weeds, this approval
applies only applicable to surface water supplies, since groundwater supplies would not have any weeds to control.
3. In groundwater fluridone is a contaminant since there is no practical reason to introduce it into groundwater.
4. Regardless of the level of fluridone that might be present in Natick's drinking water it is contrary to public health principles
to permit a contaminant to be deliberately introduced into the water supply.
5. Further, it is contrary to the principles of wellhead protection and drinking water supply protection to permit the introduction
of a contaminant into the water supply.
6. Finally, the Board felt that control methods not relying on chemical herbicides had not been fully explored in these NOI's,
and that accordingly these were not proper circumstances for consideration of the introduction of chemical herbicides into
the Town's water supply.
For these reasons we recommend that the Conservation Commission not approve the use of chemical herbicides in Lake Cochituate.
Very truly yours,
NATICK BOARD OF HEALTH
Roger J. Wade, MSPH
Director of Public Health
Cc: Board of Selectmen
2006 Letter from the Natick Selectmen to the Natick ConCom
Town of Natick
Home of Champions
Charles M. Hughes ,Chairman
John Ciccariello, V. Chairman
Carol A. Gloff, Clerk
April 19, 2006
Mathew Gardner, Chairperson
Natick Conservation Commission
Natick Town Hall
13 East Central Street
Natick, MA 0 1760
Dear Mr Gardner;
As you know, the state Department of Conservation and Recreation (the "DCR") is before the Natick Conservation Commission
requesting an approval to use various chemical herbicides to control the growth of three invasive plant species found in Middle
Pond and South Pond of Lake Cochituate. The Natick Board of Selectmen, acting in its capacity as Water Commissioners for the
Town of Natick, is sending this letter to express its grave concern with the DCR plan to use herbicides in Middle Pond and
South Pond of the Lake, and to express its support for the use of non-chemical methods to control invasive growth instead.
Our concerns and support are expressed below.
A. With regard to the use of chemical herbicides in general in these bodies of water, in summary our concerns are:
1. Two of Natick's drinking water supply well fields are located next to the Lake. The Springvale Wells are located next to
South Pond and the Evergreen Wells are located next to Middle Pond.
2. Both Middle Pond and South Pond are surface water bodies that recharge the aquifer used by both Springvale and Evergreen
3. It is estimated that as much as 65% of the Springvale well water comes from the Lake, indirectly via the aquifer.
4. Consequently, the use of any chemical herbicide in these bodies of water has the potential to contaminate our water supply.
B. Looking specifically at the proposed use of fluridone, as an example of one of the chemicals planned for use by the DCR,
we raise the following points:
1 . A study completed for the Natick Board of Health and submitted as testimony to the Natick Conservation Commission in the
Lake Treatment NOI concluded that fluridone could travel from the Lake to the Springvale Wells with just one year's usage
to treat the Lake. The Department of Environmental Protection's Office of Research and Standards reached the same conclusion
in its review of the Natick Board of Health study, and further stated a possible drinking water concern with the use of fluridone
as a chemical herbicide in the Lake for more than one year.
2. The present treatment system for groundwater at the newly upgraded Springvale Water Treatment Plant will not effectively
remove fluridone from the water.
3. Expensive carbon filtration would be effective in removing a contaminant such as fluridone from the water supply. However,
the use of carbon filtration for the Town's water supply is not possible on a permanent or even a temporary basis for the
a. The site at the Springvale Water Treatment Plant is limited preventing the construction of permanent carbon filtration;
b. The Springvale Water Treatment Plant provides 100% of the Town's water needs at certain times of the year; and
c. Temporary carbon filtration will not provide enough water to meet the Town's water needs for most of the year, even with
draconian water conservation measures;
4. Consequently, although fluridone concentrations following Lake treatment for one year will not exceed health limits set
by the Environmental Protection Agency either in the treatment concentrations in the Lake or in the lesser concentrations
estimated to be found in the ground water, given the preceding concerns, the Natick Board of Selectmen, acting in its capacity
of Water Commissioners for the Town of Natick does not support the treatment of the Lake with fluridone or other chemical
herbicides at this time.
C.The Natick Board of Selectmen understands the need to control the three invasive plant species currently found in the Lake.
Information provided to our Board indicates that non-chemical means can be effective in controlling these species. The Board
supports the use of non-chemical means to control invasive plant species within the Lake.
In conclusion, the chemical herbicide fluridone used to treat the Lake for just one year is likely to reach the Springvale
Wells; if fluridone is used in more than one year it could pose a health risk in drinking water; the Town has no present means
and very little future ability to remove herbicides in general from its drinking water; and non-chemical means are available
to control these invasive species. The Board of Selectmen, as Natick's Water Commissioners, therefore respectively request
that chemical herbicides not be used, and instead request that non-chemical means be used, to control the invasive species
present in the Lake.
Charles M. Hughes
Board of Selectmen, Chairman
Philip Lemnios, Town Administrator
Roger Wade, Director, Board of Health
Charles Sisitsky, Director, Department of Public Works
Natick Conservation Commission
Testimony from a plant biologist regarding the DCR's NOI.
Attention: Matthew Gardner, Chairman Conservation Commission, Town Of Natick
Dear Mr. Chairman,
I wish this following letter to be submitted and recorded as testimony in the upcoming hearing scheduled for April 20th 2006.
Notice of Intent to Control Nuisance Aquatic Vegetation with
Herbicides, Lake Cochituate, Natick, Ma, Prepared for DCR Lakes and
Ponds Program, Prepared by ESS Group, Inc., Project No. D 147-000.2
My name is Catherine Paris and I am a plant biologist formerly employed by the USDA Animal Plant Health Inspection Service,
Plant Protection and Quarantine in the study of biological controls of pest species. I also have an extensive background in
agriculture and ecology.
Since the late 70's I have come from believing that pesticides were useful and necessary to knowing that they rarely accomplish
what we wish them to and often have long term and lasting negative effects. I cite the example of the gypsy moth which in
1900 the Commonwealth of Massachusetts spent over two million dollars eradicating by widespread use of arsenic. Since then,
various municipalities and the US Government has spent and introduced hundreds of millions more and dosed the environment
with millions of pounds of pesticides. It is VERY likely that you will see a return of the gypsy moth to your community this
year. Another famous example is the dandelion another introduced European specie which is rampant throughout the US despite
the widespread use of herbicides. The point I’m making is that an introduced specie comes into our Massachusetts environment
and after gaining a foothold, can not only exist but spread and rapidly out compete local species throwing our long evolved
habitats out of sync. The application of pesticides appears ( but only appears) to control these invasions. In fact, what
actually happens is a large void is created. In the case of Eurasian milfoil one would see an absence of milfoil on the surface
and to look beneath the surface you’d see an area completely devoid of any plant life. As we all know, nature abhors
a vacuum. Meaning essentially that you have a lake with high levels of nutrients, plenty of sun, no shelter for the vertebrate
or invertebrates that would control an overgrowth of water weeds. In summary, a perfect habitat for a weed specie to take
over. You are back where you’ve started but much poorer and potentially less healthy than you were.
Over time we’ve learned that these invasives are best controlled with the introduction of a specie that will consume
or interrupt the life cycle of the weed. Again nature has shown us the answer because every environment is a balance of specie.
When we tip that balance by loading nutrients into a water body the first line of defense is to stop adding food for the plants
to proliferate. The second would be to introduce a weed eating insect that would flourish on these lush stands of vegetation.
Eventually, because there is a huge amount of readily available eurasian milfoil for the weevil to consume, its weevil population
would keep multiplying and thereby stop the spread and in some cases completely eradicate the milfoil. An herbicide application
prior to the introduction of a biocontrol specie is folly. It is the very large scale prevalence of the milfoil that allows
the weevil introduction to be successful.
In short, as representatives of your town folk, I want you to realize that herbicide application is not going to remove eurasian
milfoil from your lake. This milfoil is long established in the northeast. Every citizen that boated or swam in your lake
is a potential reintroduction source. Even one single plant from an aquarium could refill your swimming and boating areas.
Why not spend the money and invest in a long term solution that would be both safe and effective. It is our money afterall.
Report from the consultant to the DCR & Natick Board of Health 3/7/06.
click here to download file
Peter Shelley's letter to the DCR Stewardship Council
Richard H. Cross, Chair
Massachusetts DCR Stewardship Council
251 Causeway Street
Boston, MA 02114
CONSERVATION LAW FOUNDATION
March 2, 2006
RE: Mass. DCR Pesticide Spraying Program - Lake Cochituate
Dear Mr. Cross:
I have been meaning to write for some time to comment on the DCR's approach to invasive vegetation management in Lake Cochituate
and elsewhere. I attended the Stewardship Council's meeting at the Community Boating House last month where the matter was
discussed and came away from that meeting more convinced than ever that the Department needs to seriously re-evaluate its
pest management program from top-to-bottom.
The DCR presentation in favor of their herbicide program was more directed at justifying the conclusion that they had already
reached than it was at illuminated the costs and benefits of the various options. The presentation was unpersuasive to me
both with respect to its efficacy in ultimately controlling the milfoil, its impacts on non-target biota, its ability to control
or even understand the unintended consequences of the chemical approach, as well as its long-term cost-effectiveness. Given
the expected continued budgetary restrictions on DCR for years to come, any program that poses additional environmental risks,
generates such substantial community opposition, and costs scarce dollars for marginal, if any, long-term benefits should
be given the strictest scrutiny. I do not believe that the agency's program as it is currently designed can bear that standard.
I was heartened to hear the well-reasoned ecological perspective of Dr. Agyeman at the meeting in Boston and encourage the
Stewardship Council to take a close look at this topic through its policy committee. Poisoning DCR lakes "to save them" is
dubious public policy and should be a last resort. Indeed, we would anticipate that this strategy is only contemplated where
there are no viable alternatives and where there are compelling off-setting human health circumstances. In my opinion, the
Lake Cochituate situation - which seems to be driven by recreational use issues -does not rise to that level.
If we can be of any assistant to the Council in this process, I am happy to offer our services.
cc: Commissioner Stephen R. Burrington
Michael Gildesgame, DCR
62 Summer Street, Boston, Massachusetts 02110-1016
Professor Yuretich's recommendation on NOI
The following letter has been sent to the Chairs of the Natick Board of Health and the Natick Conservation Commission.
Richard F. Yuretich
Professor of Geosciences
UNIVERSITY of MASSACHUSETTS at Amherst
DEPARTMENT OF GEOSCIENCES
February 27, 2006
I have been reviewing the documents concerning the vegetation control proposed for Lake Cochituate in order to evaluate the
migration of proposed herbicides into the groundwater and public water supply of the Town of Natick. I am familiar with
the geology and hydrology of the lake and Springvale well field as described in written testimony prepared for an administrative
hearing concerning a Superseding Order of Conditions that was issued on March 9, 2004. The current Notice of Intent proposes
to use the chemical fluridone in addition to the other herbicides originally planned.
I have subsequently reviewed several documents pertaining to the behavior of fluridone in the environment. Fluridone has
somewhat different properties than the other chemicals that are proposed for use in Lake Cochituate. Although the numerical
data are sparse, many of the documents note that fluridone is not retained appreciably in "hydrosoils" or lake sediments,
but is released into water where "photolysis" (destruction of the compound by light) occurs. This is fine for surface waters
exposed to sunlight, but water in Lake Cochituate recharges the aquifer system, as outlined in my previous testimony, and
the water will not be exposed to sunlight by the time it reaches the town wells. Accordingly, the fluridone will likely be
preserved in the groundwater.
The documents also point to a half-life of about 21 days for fluridone. This is the time when the amount of fluridone decreases
to half its original concentration. This half-life is based upon the breakdown of fluridone by photolysis, which will not
occur in groundwater. The minimum estimate of travel time of groundwater from Lake Cochituate to the wells, as mentioned in
the testimony, is about 1 month. Accordingly, it is possible that fluridone could reach the Springvale wells without significant
degradation. Given that 50% of the water in the Springvale wells is derived from Lake Cochituate, then half of the original
applied concentration could appear in the public water supply. The NOI states that the intent is to keep the fluridone levels
in the water elevated for up to 90 days. This would serve to increase the probability that the chemical will enter the groundwater
and subsequently migrate to the town wells.
Given the possible migration into the water supply of the Town of Natick, I recommend against using fluridone and the other
herbicides to control invasive vegetation in Lake Cochituate.
Richard F. Yuretich
Professor of Geosciences
HEARINGS FOR STATE'S NEW HERBICIDE PLANS FOR LAKE COCHITUATE
The state has filed Notice of Intent (NOI) documents with the towns of Natick, Framingham, and Wayland.
These NOIs lay out a plan to use herbicides and/or other methods, on Lake Cochituate for the purpose of controlling aquatic
The original NOIs were worded to include herbicide use in both the Herbicide NOI and the Physical/Biological NOI. The Physical/Biological
NOI has now been altered to remove the herbicide reference. (See the change notice below).
Weevils have been relegated to a small pilot study status in the Physical/Biological NOI .
The herbicides proposed in the Herbicide NOI are:
Aquathol K (endothall)
Sonar AS (fluridone)
Sonar Q and PR (fluridone)
The state sought review and approval by local conservation commissions in order to proceed.
Hearings on these proposals before conservation commissions of the towns involved have alresdy occurred:
Framingham: (Passed NOI with conditions)
Natick: Rejected herbicide NOI. See our News page.
Wayland: (Passed NOI with conditions)
You may download the Natick NOIs in pdf form below.
The state requesting a continuance to March 2, 2006 at a February 2 meeting.
They wrote "This is to inform you that due to a recent request from the Natick Board of Health for additional information
about the NOIs submitted to the conservation commission regarding Lake Cochituate, we will be requesting a continuance of
the hearing from this Thursday, February 2nd until Thursday, March 2, 2006 at 7:30 p.m. That will allow us sufficient time
to acquire and present the information to the board of health so that they can advise the conservation commission about the
CHANGE TO THE PHYSICAL AND BIOLOGICAL NOI
In section 3.3
on page 10, under Year 1.
• Hand-pulling, if plants are not completely controlled by the herbicide Sonar.
• Hand pulling in locations to be decided, based on the density and distribution of plants.
• Diver Assisted Suction Harvesting in locations to be decided, based on density and distribution of plants.
download Ntk Herbicide NOI
download Ntk Phys./Biological NOI
An extraordinary symposium
September 19, 2005
Protect Our Water Resources (POWR) sponsored a symposium at the Natick Town Hall on September 19th, 2005
John Todd Ph.D. Ocean Arks International, Research Professor and Distinguished Lecturer at the University of Vermont
Jonathan Todd Senior Partner John Todd Research & Design.
Martin Hilovsky President of EnviroScience, Inc.
Dr. Todd is a globally recognized leader in the field of ecological design and the author of over two hundred technical and
popular articles on biology and planetary stewardship. He has degrees in agriculture (McGill University), parasitology & tropical
medicine (McGill University) and a doctorate in fisheries and ethology from the University of Michigan. He has received two
honorary doctorates in science and engineering respectively.
Jonathan Todd heads the company called John Todd Research and Design. It is involved with designing and building natural systems
based wastewater treatment and ecological watershed management.
Martin Hilovsky is president of EnviroScience, Inc., a 25 person ecological consulting firm located in Northeast Ohio. In
addition to general responsibility for business operations, Martin Hilovsky acts as manager of EnviroScience's Lake Management
Division. He holds Bachelors and Master Degrees in Biological Science and Aquatic Ecology from Kent State University. He has
been invited to speak and has presented papers at numerous scientific conferences, state and national association meetings,
and various symposia dealing with water quality and lake management issues. He is an internationally recognized authority
in Eurasian Watermilfoil management, particularly in the area of biocontrol using the native weevil Euchrychiopsis lecontei.