ISDS 



Data Availability 



Data on the land, soil, and water resources of the state is inconsistent 

 and requires updating. Although progress is being made in improving the quality of 

 data available for decision making in critical areas, and in the Scituate reservoir in 

 particular, development of an accurate resource data base should be considered a very high 

 priority for the entire state. 



Data on the condition of systems, reasons for failure, and the effects of 

 malfunctioning systems on groundwater, water supplies, and habitats is 

 rudimentary. A comprehensive data tracking system must be developed in order to 

 facilitate regulatory enforcement and to enable decision makers at the state, regional and 

 local levels to target efforts effectively, assess results of model programs, learn the 

 strengths and weaknesses of various approaches, and balance priorities among the range of 

 non-point source pollution problems requiring attention. 



Program Structure and Function 



Although "critical areas" are specifically referenced in the language of 

 the ISDS regulations as requiring special attention, neither the areas nor the 

 procedures are defined. Only public water supply reservoirs are currentiy accorded 

 special provisions. As presendy implemented, the ISDS regulatory program is not 

 effective in protecting water supplies, other critical receiving waters, or coastal watersheds. 



In critical areas in particular, DEM must take the lead in strengthening 

 ISDS regulations, because most towns have not moved beyond the state 

 requirements despite their authority to do so. Reluctance is due to lack of 

 technical expertise and staff support and to political pressure. 



The regulatory revisions proposed by the ISDS Task Force, which 

 represent a vigorous attempt to address current problems, still would 

 consider only the current status of critical areas, and would not adequately 

 address potential effects of systems on areas which may become important public water 

 supply sources, private well recharge areas, or key habitat resources in the future. As 

 such, even the proposed Task Force regulations would allow certain areas 

 of the Bay watershed to remain vulnerable. 



The current regulatory system is strongly dependent on the use of 

 percolation tests to determine site suitability, and relies heavily on the 

 accuracy of information provided to the state by engineers and designers 

 insufficiently trained to make adequate hydrogeological assessments of site 

 parameters. As such, it is vulnerable to potential data inadequacy or inaccuracy, and to 

 misinformation. 



Current evaluation methods and regulatory requirements are unable to 

 deal adequately with cumulative effects of ISDS sitings, particularly where 

 large systems, or multiple systems serving subdivisions are concerned. 



Sinnlarly, DEM policy on the development of package treatment plants in areas of multiple 

 ISDS failure is insufficientiy clear. 



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