The Bare Hill Pond drawdown performed yearly to reduce nuisance aquatic plants, ecologically harmful levels of phosphorus, and the chance of algae blooms, has been stopped at the 3-foot mark and will not resume this year. It was called off almost as soon as it began, in early October, after problems with permitting and equipment made it impossible to continue.
Normally, the drawdown begins in late September or early October. Dam barriers are removed for a so-called gravity drawdown of 3 feet; then, the pump starts and lowers the water by another 3½ feet—for a total “deep drawdown” of 6½ feet—before November’s end. The winter freeze kills or weakens the exposed plants—if freezing temperatures arrive and persist. When all goes according to plan, the pond starts refilling in February after the dam’s barriers are put back in place and rainfall and underground springs restore the water level.
But this year, events intervened to interrupt the drawdown, which seemed especially important to achieve after the documented increase in the pond’s nuisance plants over the past several years.
First the Massachusetts Department of Environmental Protection appealed the Harvard Conservation Commission’s order of conditions allowing the drawdown, halting it while the appeal plays out. Then, as the Bare Hill Pond Watershed Management Committee gathered evidence to convince MassDEP to withdraw the appeal, equipment in the pump house failed irreparably.
It could take up to six months, members of the committee said, to secure bids and funding and to replace the broken equipment, a 17-year-old, variable frequency drive that controls the pumping system, at a probable cost of $40,000 to $60,000. Addressing the objections raised by the DEP appeal should take much less time, according to Bare Hill Pond Watershed Management Committee Chair Bruce Leicher.
At a Nov. 2 meeting of the committee, Leicher summarized the recent events and explained how the committee intends to address them. The appeal was issued by the central regional office of MassDEP, Worcester, Oct. 3 and is, Leicher said, “based on generalized concerns” by the Division of Fisheries and Wildlife that says drawdowns of more than 3 feet should be allowed only when an applicant proves they are beneficial and the drawdown qualifies as “restorative” by state standards. The committee, Leicher said, disputes MassWildlife’s interpretation. “The only evidence in the record is one of ecological restoration over the last 20 years,” he said at the Nov. 2 meeting. MassWildlife does not issue the permit, but supplies MassDEP and the Harvard Conservation Commission with input; Leicher said the committee had asked to consult with MassWildlife, but it did not respond.
A MassDEP appeal and a committee’s rebuttal
A letter from the committee to DEP details its rebuttal to the appeal. MassWildlife, the letter said, “did not introduce direct evidence of any specific harm to fish during the 20 years in which drawdowns were conducted.” As proof, the letter cited data from organizers of fishing derbies showing no significant decline in fish and noted the presence of heron and bald eagles. The letter also asserted that MassWildlife had mistakenly applied standards for “recreational and/or shoreline maintenance” drawdowns to Bare Hill Pond, which is not drawn down for convenience but to kill or weaken nuisance plants and reduce phosphorus. The literature cited by MassWildlife as a reason for the appeal “specifically notes that absence of site-specific data [as] the motivation” for questioning the drawdown. But, “At Bare Hill Pond there is actual long term data and evidence of the beneficial and restorative effects of carefully monitored drawdowns over the past 20 years.”
The committee’s letter said MassWildlife had ignored the 50% reduction in phosphorus since its high point in 1999 and “conflated” the poor results in reducing invasives in 2023 “with the project being unsuccessful” instead of acknowledging the increase “occurred primarily in the non-drawdown zone due to the mechanical failure of the pump that led to the refill of the pond prior to the freeze” in December 2022.
Accompanying the letter was a five-page list of how the drawdown complies with all applicable Wetlands Act and Massachusetts Environmental Policy Act regulations, including those for a restorative drawdown.
The ball is now in MassDEP’s court as it continues its review; it must decide whether to withdraw its appeal or issue a new order of conditions limiting the drawdown’s depth. Representatives from ConCom and the committee recently met at the pond with MassDEP’s wetlands section chief. The visit gave them an opportunity to “show evidence of environmental restoration” and explain the rationale for the drawdown, Leicher said.
Reducing weeds without a deep drawdown
Beach-goers, and those who routinely navigate boats, swim, or live by the pond had noticed the proliferation of weeds this summer. Evidence backs up their observations.
Yearly reports by the independent firm Aquatic Restoration Consulting, or ARC, track phosphorus levels, native and invasive aquatic plants, sediment, and the condition of wetlands at the pond. And the data confirms the increase in nuisance plants. (Volunteers count frogs and turtles, and derby organizers collect data on the fish.) According to ARC’s 2023 report, aquatic plants were most numerous between 1998 and 2004. Since drawdowns began in 2006, invasive aquatics have steadily declined except in the last three years: With the exception of an aquatic plant called pond weed, all measured plants have increased between 2020 and 2023. Sure enough, drawdowns during this time have been disrupted by a combination of equipment failure and weather, including excessive rain and warmer temperatures.
Members of the committee defend drawdowns as the best bet against weeds and algae blooms. But last year, committee Chair Leicher told the Press—after a malfunctioning valve interrupted another drawdown—that while drawdowns are the best attainable hedge against overgrowth and algae blooms, they have their limits. The accumulation of phosphorus on the pond’s floor, much of it formerly farmland, and the climate’s warming trend will probably make the drawdowns less reliable in the future.
The committee presented slides to the Select Board Nov. 7 showing that it will work with the harbormaster, Bob O’Shea, and other town officials to investigate other methods for controlling aquatic plants within the ropes at the town beach. O’Shea affirmed that he was looking into solutions “for the beach area only,” including aqua vacuuming, performed by divers, and dredging. Herbicide treatment is noted on the slides, but using it would be more time-consuming to pursue; Town Meeting enacted a moratorium on it in 1983.
After Leicher’s presentation, Select Board member Erin McBee and ConCom Chair Eve Wittenberg thanked the committee for its work and encouraged it to keep trying to resolve the appeal. Leicher said the committee will continue to seek funding. “I’ve reached out to the state that gave us the original grant [to build the pump house]. It’s crazy that DEP funds us to build a pumping station and someone else then questions our using it.”
