The front page of the Boston Globe last week presented a powerful, timely and cautionary tale about  two liquefied natural gas terminals  that sit off the coast of Gloucester and Salem. Those terminals are the tangible reminder of a massive push undertaken by energy industry insiders to build such terminals.  The intensity of that push, which began to build around 2002, becoming most intense during the 2004  to 2007 period and then petering out in the years since, contrasts sharply with the reality described in the Globe article: that those two offshore terminals have sat idle for the last two years.

That push to build LNG import facilities, which was such a mania in energy industry circles circa 2005, yielded some crazy ideas, like the proposal to hollow out a Boston Harbor Island and the infamous Weavers Cove project in Fall River. The offshore terminals, while the least bad of those proposals, reflected short sighted thinking detached from careful regional planning.  Both in terms of the need for these facilities and design decisions like regulators not forcing the projects to share one pipeline to shore instead of (as they did) twice disturbing the marine environment to build two duplicative pieces of infrastructure.

Today, the hue and cry is no longer about LNG, instead we are bombarded with impassioned demands for more natural gas pipelines as well as more measured discussions of the need for “smart expansions”. Will we have the collective intelligence to be smarter and more careful this time? Will the permitting process force consideration, as the law requires, of alternatives that make better use of existing infrastructure and pose less risk to the environment and the wallets of customers? Fixing natural gas leaks and becoming much more efficient in our use of gas is a key “supply strategy” that needs to be on the table and fully examined before committing to new pipelines.

And as it so often is, the overarching issue here is protecting future generations by addressing the climate issue. Science and prudent energy analysis, makes it clear that we need to put ourselves on a trajectory to end the burning of fossil fuels, including natural gas by the middle of this century. Given this reality every proposal to build massive and long-lived facilities to import more of those fuels must be viewed with great skepticism.

My son’s third grade class is looking for “juicy” adjectives, and I found one.  Again and again, journalists are describing the Massachusetts Governor’s 21st Century Transportation Plan, which proposes to raise revenue for our chronically underfunded transportation system, as “ambitious.” Not the kind of “ambitious” your mother admired in you when you were a college student, but the “ambitious” that implies hubris. As in asking for a lot. Maybe even too much. Insisting that the Governor’s plan is “ambitious” immediately gets people thinking about how they can cut it down to size. So before the knives come out, having carefully reviewed the plan and understanding the real needs of our transportation system well, let’s take a look at what’s really in there:

• The plan proposes to increase Chapter 90 funding for local street maintenance and associated projects from $200 to $300 million per year.  The Massachusetts Municipal Association, however, just recently estimated the actual need to be $562 million per year.
• Likewise, the Governor’s plan only dedicates 23% of the capital to strategic expansion projects, the rest is all maintenance of roads, bridges and transit infrastructure, replacement of old trains and buses, capacity upgrades, and other costs of the current system.
• More importantly, only 4% of the money set aside in the Governor’s plan for operations is related to strategic expansion projects.
• The plan also assumes that good and necessary transportation projects which have long been recommended by transportation planners and economists, such as the Red-Blue Connector and the Urban Ring, would be left unfunded over the next ten years.

I don’t know whether “reasonable” or perhaps “conservative” would be juicy enough adjectives for my son and his friends, but they would surely be a more accurate description of the Governor’s transportation plan.

When Governor Deval Patrick stood before the Legislature and the people of Massachusetts last week to offer a bold proposal to raise $1 billion per year to fund critical investments in transportation, he struck a skillful balance between the pragmatic and the visionary, appealing to us as both taxpayers and investors in a thriving Commonwealth.  The Governor asked his constituents to “Imagine if you could depend on a bus or subway that came on time, was safe and comfortable… if the Green Line ran to Medford and the commuter rail ran to Springfield,” among other improvements. He made sure to emphasize that everyone would benefit from a 21^st century transportation system, whether they drive a car or take public transit, from one end of the state to the other. And he proposed that everyone pay their share, according to their ability.

It’s a good proposal and a badly needed one. The question now is how to get the buy-in we need to make it happen. Not surprisingly, it’s not too hard to find political opponents and citizens of the Commonwealth to speak out against the proposed tax increases. Who wants a tax increase? It’s like asking someone whether they want a root canal. But if you ask a person in that special dental pain whether she would be willing to pay a fair price to make it go away – indeed to be able to enjoy biting into a delicious crunchy apple —she would almost certainly agree that her investment would be worth it.

With Massachusetts’ transportation system so woefully underfunded for many decades, we are all in that special pain. Crumbling bridges, decaying train cars, vanishing bus routes and unfinished projects are daily reminders that we’ve got a problem that needs to be fixed. And we all have our own version of that delicious apple:  our mode of transportation that gets us where we need to go, when we need to go, safely, reliably and affordably. The problem is that people want the pain to go away – indeed, they want the apple! – but, politicians fear, they don’t want to pay for it.

In fact, a MassINC poll conducted last year showed that 62% of people surveyed said that they would be willing to pay more than they are paying now to improve the transportation system – up to a point. So, maybe we should be asking people not whether they agree with the Governor’s proposal to raise taxes, but rather, whether they agree that a working transportation system is a worthwhile investment. More frequent trains. Easy connections between distant parts of the state. Fast access to the airport. And why stop there? What about cleaner air, less congested roads and more vibrant communities with thriving businesses and the jobs they bring? Let’s talk about the benefits, like the Governor started to do, and help the savvy taxpayer see how her investment will pay off – now and in the future. Our legislators need to hear from the transit champions. C’mon…we know you’re out there.

There is an epidemic of truth telling underway, globally, nationally and in Massachusetts.  And as hard as some of that truth is to hear it is a very healthy and important exercise.

On the global level the business and political leadership is finally waking up to the deep and systemic threat of a changing climate.  The 2013 Global Risks Assesment from the World Economic Forum describes how business and political leaders see climate risk as the only thing competing with “risk of financial collapse” as the biggest threat facing the world economy:

respondents also identified the failure of climate change adaptation and rising greenhouse gas emissions as among those global risks considered to be the most likely to materialize within a decade. Compared to last year’s survey, the failure to adapt to climate change replaced rising greenhouse gas emissions as the most systemically critical. This change in our data mirrors a wider shift in the conversation on the environment from the question of whether our climate is changing to the questions of “by how much” and “how quickly”.

Meanwhile back in America, the experts preparing the National Climate Impacts Assessment dropped a terrifying draft report on the government and the internet, seeking public comment. That report, summarized in a “Letter to the American People,” described how the changing climate is already visible:

Americans are noticing changes all around them. Summers are longer and hotter, and periods of  extreme heat last longer than any living American has ever experienced. Winters are generally shorter and warmer. Rain comes in heavier downpours, though in many regions there are longer dry spells in between.

 The report then goes on to lay out in excruciating detail the impacts of global warming that have been observed and are anticipated by very solid science – laying out the facts in over a thousand pages of text (147 MB PDF) and 32 alarming charts and graphs.

So what does all this have to do with transportation infrastructure, and paying for it through taxes, in Massachusetts?

It matters because the transportation sector is the second largest (or largest depending on what definition of “sector” you use), and fastest growing source of greenhouse gas emissions in Massachusetts. If the Bay State is going to meet the mandate of the Global Warming Solutions Act and live up to its Clean Energy and Climate Plan we will need to invest in a modern and effective transportation system.  The Governor and his Department of Transportation have laid out the formidable challenge of updating a chronically underfunded and neglected system to meet these challenges in a startling clear and powerful document titled, “The Way Forward: A 21st-Century Transportation Plan”.

The job of solving our transportation infrastructure crisis brings together a powerful coalition.  Citizens who just want a transportation system that will let them lives,  the business community who are shouting from the front page of the newspaper about how the weaknesses in our transportation system are undermining our economy and need to be addressed through investment and Climate Hawks who want Massachusetts to again lead the nation and the world.  Leading, as it did at the time of the American Revolution and as it did as the cradle of the movement to abolish slavery, both through our words and thoughts but also lead by example by building a better Commonwealth with the clean and climate-protective transportation system of the future.

A few weeks ago, Springfield, MA, was rocked by a natural gas explosion that destroyed a building, ruined a city block, and was hailed as a miracle because no lives were lost.

The pipelines that lie below our communities, always out of sight, came suddenly came into focus. The explosion reminded us of the sobering reality that our streets are not always safe. Despite smart investments in energy efficiency and new energy technologies in New England, when it comes to natural gas, whose infrastructure is among the oldest in the nation, we have been reluctant to prioritize investment in replacing and repairing the pipes and valves that we rely upon not only to heat and power our homes, but to keep us safe.  When it comes to natural gas efficiency and investment, there is much more we can do – so much more.

We need to improve safety, increase efficiency, and reduce the risk to communities and to our planet. It is my belief, as well as that of my colleagues here at CLF, that we can and should make our communities healthy and safe from the unnecessary risk of explosions from old and leaky pipelines. This is vital, for two reasons.

It’s vital because methane, the major component of natural gas, is 25 times more potent as a global-warming causing gas than CO2. In a year that has broken so many temperature records, and in an age when climate is showing the signs of human distortion, we are constantly reminded of the strain we are placing on our global ecosystem. It is a strain we need to urgently reduce.

It is also vital to replace and fix pipes leaking natural gas because it is so combustible. Springfield reminded us of this fact. So too did the explosions that that rocked San Bruno, California in 2010, Allentown, Pennsylvania, in 2011, and Gloucester, MA in 2009, and most recently, Sissonville, West Virginia, to name only a few. These explosions are reminders of the serious care and attention that our natural gas infrastructure needs. If we fail to provide them with that care, we gamble with our safety, and with our lives, as this image from the San Bruno explosion vividly shows.

As my colleague Shanna Cleveland recently said, “The need for action is particularly acute in Massachusetts where over one-third of the system is considered ‘leak-prone’—made up of cast iron or unprotected steel pipe.” The leaks in Massachusetts are so significant that the gains by efficiency programs put in place by Massachusetts regulators are disappearing into thin air. A report released by CLF by that name (Into Thin Air, available to download for free here) documents how these leaks, known as “fugitive emissions,” are being borne not by the utilities, or by the regulators, but by consumers. Utilities pass the cost of lost gas onto ratepayers to the tune of $38.8 million a year. Here’s an infographic from that report:

Another report by Nathan Phillips of Boston University combines Google Earth and research into a compelling visualization of just how prevalent these leaks are.

Like the explosion in Springfield, Nathan’s map documenting the 3,356 separate natural gas leaks under the streets of Boston reminds us that, as we walk or drive down the street, we are often driving through an invisible cloud of natural gas leaking from aging pipes. If you are like me, to accept the avoidable risk of a predictably volatile gas is deeply unsettling.

With the exuberance for cheap, domestic natural gas on the rise, proposals for new massive interstate pipelines are in the works. Houston-based Spectra, a natural gas pipeline company, is proposing a $500 million expansion for Massachusetts alone. Before we go down that route, I would like to make three simple suggestions.

1) Whether the natural gas industry ever delivers on its claim of being more environmentally friendly than coal or oil depends on how well natural gas infrastructure addresses leaks. We develop more accurate tools for assessing the greenhouse gas emissions from pipelines.

2) Not only is investment in new pipelines and power plants expensive, but it comes with serious and lasting environmental consequences whose costs are too often discounted or ignored.  Before we blindly rush ahead with investments to expand, we need to look closely at the full range of costs.

3) Finally, we would do well to remember the lessons we have learned so well about the environmental and financial benefits of looking to efficiency first. Efficiency, both in the traditional sense of reducing our use of natural gas, and in the sense of maximizing the efficiency of our existing natural gas infrastructure by replacing outdated infrastructure and repairing leaks will reduce risk, reduce costs, reduce environmental impacts and put people to work throughout the region.

As the explosions in San Bruno, Gloucester, Allentown, and Springfield have reminded us, this is about the safety of our communities. We should not let promises of short-term profit in new projects trump both the near-term risk of thousands of leaks and the long-term sustainability of this region and stability of our climate.

Ignoring leaky natural gas infrastructure is risky business. Let’s fix what we have, and maximize our efficiency gains, before aggressively expanding. We’ll be more sustainable, and safer, that way.

Imagine this: the Governor of Massachusetts addresses the people of the state about an important issue. From the television screen he looks us all in the eye and discusses . . . transportation infrastructure. Improbable? How about if this happened back in the days of when Boston had 5 commercial channels and one public TV station and a statewide address by a Governor was a very big deal? It may be hard to believe that a subject that wonky and technical could be the focus of that sort of hot and intense attention. But it happened.

The year was 1970 and the Governor was Frank Sargent, the strong leader who years later served as Chairman of the Board of CLF. In that dramatic 1970 speech Governor Sargent accepted a report from a special task force reviewing plans to build a massive network of highways in and around Boston and launched a planning effort that set the course of transportation planning for decades to come. Memorably, Governor Sargent, a former head of the state agency that built and operated highways (then known as the “Department of Public Works”) confessed: “Nearly everyone was sure that highways were the only answer to transportation problems for years to come. But we were wrong.”

The powerful story of that speech, the events that precipitated it and most importantly the massive planning process that followed it is told in The Roads Not Taken, the core story in Turn Signal, the Winter issue of ArchitectureBoston, the quarterly publication of the Boston Society of Architects. And the rest of the issue is well worth your time – both for the eloquent essays, like the story of the activists who fought off the highways that were threatening their community, and the photo essays that document what was saved when the highways were stopped.

The good folks at ArchitectureBoston have done something very important here. The Boston Transportation Planning Review (the “BTPR”) that grew out of that  very unique moment set a powerful precedent for the nation and charted a course that has literally shaped the face and communities of Greater Boston. CLF has had a front-row seat at the implementation process for the BTPR and dove into that process even deeper, unsurprisingly given the importance of the transportation system to our mission and the unique fact that Governor Sargent served as Chair of CLF’s Board of Trustees after leaving office.

As Stephanie Pollack, who worked here at CLF with great distinction for many years, powerfully describes the challenge going forward in an essay in Turn Signal:

Forty years on, the time has come for the Commonwealth to fulfill three of the most important unkept promises: institutionalizing open and visionary planning, healing the scars still left in neighborhoods cleared for the cancelled highway projects, and completing and funding the state’s public transportation system.

This theme of the need to finish the job of the BTPR by providing needed funding to our transportation system and institutionalizing good planning practices was picked up in a recent Boston Globe Op-Ed by former Governor Michael Dukakis and another elder statesman of Massachusetts government who began his career in the BTPR era, Stephen Crosby. Dukakis and Crosby wrote:

With transportation issues again at the top of the Commonwealth’s political agenda, we should look back at those long-ago events not out of nostalgia, but as a roadmap for the equally momentous decisions we face today. After decades of investment, Massachusetts has a vastly improved transportation system that includes an extensive network of highways, the MBTA, and regional transit systems serving virtually every part of the state. But this system and the people and businesses that depend on it are in trouble. From aging bridges in Springfield to the T’s financial woes, the state is paying the price for neglecting the basic maintenance and financial backing that any transportation system requires.

And we can’t just maintain what we’ve already built. For a first-class economic future, the Commonwealth requires a first-class transportation system. As state transportation officials have already spelled out, this future will rely heavily on public transportation and will focus highway funds on maintenance rather than expansion. Massachusetts needs to expand existing transit and build high-speed rail to serve the entire state. With so many projects awaiting action, the Commonwealth once again needs to set honest and rigorous priorities for transportation investment — and create a long-term financing plan to efficiently implement those priorities.

This is indeed the bottom line: building thriving communities will require vision, careful planning and investing in our transportation system. This is not the most fun message (folks may claim otherwise but no one really enjoys slowing down to plan or paying for investments) but it is a solid truth — if we want to keep moving forward we need to build, maintain and operate the system that literally keeps us moving.

Frank C. Grace, www.trigphotography.com

Coal-fired power is dying, not only across the nation, but across New England as well.  The region’s coal-fired power plant fleet has started to succumb to the costs of operating a coal-fired dinosaur in the age of energy efficiency, growing renewable electricity generation, and–for now–low natural gas prices.

Predominantly coal-fired Brayton Point Station in Somerset, Massachusetts, is the state’s largest single source of carbon emissions (producing over 6 million tons in 2010). Another harmful pollutant emitted by Brayton Point is particulate matter, which is measured daily by monitors that continuously check the opacity of the soot coming out of the plant’s smokestack. Brayton has been violating their limits for emitting that soot, and failing to monitor their emissions of several other harmful pollutants. Yesterday, CLF filed a notice of intent to sue Brayton’s current owners, Dominion Resources, for those violations. CLF’s upcoming lawsuit is just the latest in a growing list of bad news for Dominion and Brayton Point.

As New England’s other coal plants started to close or teeter on the edge of closure, Brayton Point Station was expected to be the last coal plant standing in the region. It is New England’s largest coal-fired power plant, and in the past decade its current owners, Dominion Resources, sank over $1 billion in pollution control upgrades into the behemoth. While Brayton Point does not have the kind of legal protection from market realities that PSNH exploits to prop up its dirty old coal generation in New Hampshire, many had assumed that Brayton Point was well-positioned to survive in the changing power generation landscape.

source: EPA and ISO-NE data

But the relentless pressure of low natural gas prices and the costs of starting up and operating an enormous coal-fired power plant have begun to affect every corner of the coal generation market in New England, and Brayton Point has not been spared. The plant’s “capacity factor,” which reflects the amount of power the plant generated compared to the amount of power it could have generated if used to its full potential, has taken a nosedive over the past three years. A plummeting capacity factor means that it is a better economic choice for a plant’s owners to keep it idle most of the time than to operate.

Dominion Resources, clearly, has seen the writing on the wall for coal in New England. After signing a binding agreement to cease coal operations at Salem Harbor Station as a result of CLF’s lawsuit against that plant, Dominion sold the Salem plant earlier this year. Following closely on the heels of the Salem sale, the company put Brayton Point on the market in September. While Dominion is marketing Brayton as a modern coal-fired power plant due to its recent billion-dollar pollution control investments, UBS recently assessed [PDF] the value of those investments (and the plant itself) at zero.

Brayton Point’s plummeting capacity factor and bleak sale prospects reflect both the current power of low natural gas prices and the weakness of these old, out-dated coal plants.  That trend will continue as the New England energy market continues to move forward with better integration of efficiency, conservation and renewable generation. Dark clouds are rising over Brayton Point. In the meantime, CLF and our partners will work diligently to hold the Brayton Point power plant accountable for producing its own dark clouds of pollution in violation of the law.

As the exuberance for “cheap, domestic” natural gas has heightened, so has pressure to build new pipelines and power plants.  Often lost in the frenzy, however, is the sobering reality that our existing natural gas infrastructure is in need of some serious care and attention.  A recent study highlighted the fact that the pipelines that deliver gas to our homes and businesses are riddled with thousands of leaks.  A large number of those leaks can be blamed on a system that still includes significant amounts of cast iron–some of which dates back to the 1830s.

Explosions in Philadelphia and Allentown, Pennsylvania in 2011 as well as a 2009 explosion in Gloucester, MA were traced to aging cast iron.  Coupled with the massive San Bruno explosion, the issue spurred the U.S. Department of Transportation to issue a “Call to Action” urging regulators and pipeline operators to accelerate the repair and replacement of high risk pipe.  Given this sense of urgency, the estimated timelines for replacement seem interminably long:

•  81% of the remaining cast iron is buried in only 10 states:

• Of these states, seven have implemented programs with deadlines for complete replacement:

• New Jersey – 2035; New York – 2090; Pennsylvania – 2111; Michigan – 2040; Illinois – 2031; Alabama – 2040; Connecticut – 2080; Missouri – 2059.

Really? Decades to get the job done, at best?  And about a century to fully “modernize” pipes in some states? Sad, but true.

Though public safety is the primary driver behind pipe replacement and repair, whether the natural gas industry ultimately delivers on its claims for being less damaging to the climate than oil or coal depends on how well natural gas infrastructure addresses leaks.  In addition, those who are clamoring to blindly forge ahead expanding new natural gas infrastructure before we’ve fully assessed the condition of our current system would do well to remember the lessons that New England has already learned so well about the financial and environmental benefits of looking to efficiency first.  Not only is investment in new pipelines and power plants expensive, but it comes with serious and lasting environmental consequences whose costs are too often discounted or ignored.  Why not maximize opportunities for operating the existing natural gas system more efficiently first, before building (and paying for) more?

Despite the fact that we know natural gas prices are predictably volatile, several states have begun to take action to lock energy customers into long-term commitments to buy natural gas-fired power, thus locking them into paying for the fuel even when the price spikes.  For example, here in Massachusetts, one legislator has championed the idea of providing 10-20 year long term contracts for a new natural gas plant.  The problem with signing a long-term contract for electricity from gas is that while customers benefit when the cost of gas is low, they suffer when the price spikes, as it inevitably does.  That’s notably different from long-term contracts for renewable energy which typically have a guaranteed, fixed price.

Proposals for new massive interstate pipelines are in the works as well.  Spectra, a Houston-based natural gas pipeline company is proposing a $500 million expansion for Massachusetts. And all the lines on the map for proposed expansions of pipeline leading from the Marcellus Shale to the Northeast rival the Griswold Family Christmas lights display.

Before we spend billions on new infrastructure chasing the next gold rush, we must repair and rebuild our existing infrastructure and examine the tried and true tool of efficiency.   A recent study on the potential for natural gas efficiency in Massachusetts showed that efficiency could reduce winter electric demand enough to support the increased use of gas on the system without building new infrastructure:

From Jonathan Peress's presentation at the Restructuring Roundtable on June 15, 2012

But there is a risk that regulators will not fully take these very real benefits into account as they review and approve the latest energy efficiency plans.  Indeed, traditional energy efficiency naysayers are using the low price of gas as an excuse to call for reduced investment in efficiency.

The bottom line is that natural gas does have a role in our energy future, but it  is one that must be carefully managed and minimized over time if we are to have any hope of averting climate catastrophe.  In the meantime, before we jump to expand new natural gas infrastructure, we need to look closely at what we already have in the ground and apply the lessons we’ve learned about efficiency.

In 2010, CLF and three other Massachusetts conservation groups walked away from water policy discussions, terminally frustrated that the talks would produce any meaningful change that would stem the increasing trend of streams being drawn dry by public and private water suppliers.  To his credit, Governor Patrick encouraged us to come back to the table with a promise that the fundamental protection for fish provided under the water supply law, the so-called “safe yield” limit, would be interpreted by the state to protect fish populations.

The Commonwealth of Massachusetts has now released the long-awaited fruits of those renewed discussions: the “Sustainable Water Management Initiative” Framework. The Commonwealth promotes this initiative, called SWMI, as a “substantial improvement” on the regulatory framework for providing for essential public water supply services while protecting the Commonwealth’s freshwater fish and other aquatic populations. But is it? What benefits does SWMI produce over current conditions? Does this effort still fall short of the Governor’s promise?

On the positive side, SWMI vaults Massachusetts into the forefront in the country in my opinion with respect to its knowledge base of its rivers and streams. The state’s partnership here with the U.S. Geological Survey has produced a set of stream and stream flow analytical tools and a streams data base that allow the state to understand the ecological impacts of various flow regimes  in a stream, very close to the gold standard.

Similarly, Massachusetts regulators and biologists are now much better informed on the risk to wildlife and river ecosystems associated with water withdrawals for water supplies. It turns out that these aquatic biological communities are much more sensitive to stream flow fluctuations than previously assumed. While this linkage might have been qualitatively suspected before, the last two years of analytical work have now unequivocally quantified that fragile connection.

Massachusetts also has demonstrated through this process that it has some remarkable and dedicated public employees who performed the work with the highest level of professional skill. The Commonwealth is in very good hands at a technical level.

Finally, this initiative will help ensure that some of the highest quality streams in the Commonwealth will be protected to a greater degree than they are today against degradation. While the additional levels of protection will depend on the regulations that are ultimately passed and the implementation of those regulations by the agency, SWMI will provide another level of protection to those near-pristine stream segments.

Where the technical side of SWMI is robust and innovative, however, the policy side of SWMI is compromised and unlikely to produce significant ecological protection in more heavily impacted stream segments or restore stream flows to rivers that are currently being drawn dry by water supply withdrawals.

The “safe yield” tool in SWMI, which the Governor Patrick assured us would include an environmental protection factor, doesn’t really protect the environment. “Safe yield” is a stream flow calculation that is meant to set a maximum amount of water that can be diverted from a water source without adversely affected native biota.

SWMI throws out this tool as a regulatory limit for all practical purposes in many rivers including, for example the Ipswich River, an important water body that water suppliers drain every year in the summer. This results from the fact that SWMI averages the safe yield calculation over the whole watershed and on an annual basis. Because this averaging includes the late winter and spring floods, it shows high levels of safe yield even when a river is going dry in August.  It just isn’t a protective approach in any sense.

SWMI and the Commonwealth rely on other tools and regulatory tactics to avoid this result by requiring water suppliers to minimize their adverse stream impacts “to the maximum extent practicable.” The policy also goes to great length to protect water allocations from the 1980’s when the water supply law was first passed. There is nothing in the law that requires this continued grandfathering of water withdrawals in situations where there is harm to streams and such an outcome is just not good enough.

Massachusetts is fortunate to have abundant natural water supplies, receiving some 44 inches on average a year–Los Angeles gets about 10-11 inches. There is no real conflict between essential water services and healthy stream flows in Massachusetts that cannot be technically solved at reasonable costs. Unfortunately, however, while the framework may drive water use down, SWMI seems to reduce rather than increase the incentives water suppliers and municipalities have to use water smarter. All CLF can do at this point is wait to see whether the Commonwealth demonstrates through its implementation of SWMI that CLF’s concerns are misplaced.

MassDEP and the Executive Office of Energy and Environmental Affairs worked hard to find a path forward that municipalities and conservationists could both embrace. And the answers, needless to say, are not easy. The politics of water supply in Massachusetts are complex and often confrontational as they are in most states. Nevertheless, we had hoped for more for the Commonwealth’s rivers and streams.