Archive of Massachusetts ENvironmental Data

The Archive of Massachusetts Environmental Data

(DRAFT) MA Impaired Waters: Trends, Causes, and the CSO Connection

This post is in DRAFT status. It has not yet been fully completed and reviewed.

Recent development: In April 2025, EPA finalized a Statewide Total Maximum Daily Load for Pathogen-Impaired Waters in Massachusetts — a single framework cleanup plan covering all waterbodies impaired by fecal coliform and E. coli. Because bacterial contamination is the most common cause of impairment in the state, this action could formally resolve the TMDL requirement for hundreds of assessment units. Whether it leads to measurable improvements in water quality depends on subsequent permit revisions, infrastructure investment, and enforcement. The data below reflects conditions through the 2022 reporting cycle, before this statewide TMDL was finalized.

Massachusetts has been formally identifying (see also the state TMDL website) waterbodies that fail water quality standards since at least 2000. Under Section 303(d) of the Clean Water Act, states must submit a biennial “303(d) list” to EPA identifying every waterbody that fails to meet its water quality standards — and for each, develop a Total Maximum Daily Load (TMDL), a cleanup plan specifying the maximum pollutant load a waterbody can receive and still meet standards.

The 303(d) list is an important complement to data on regulatory activity (permitting, inspections, enforcement): it reflects measured environmental conditions rather than government actions. The data used here comes from MassGIS, which publishes each approved reporting cycle as GIS shapefiles with associated attribute tables. So far, the available reporting cycles are 2010, 2012, 2014, 2016, 2018, and 2022 (the 2020 cycle was never published by MassGIS). This analysis thus covers 6 reporting cycles spanning twelve years.

The code used to produce this analysis can be viewed and downloaded here


Background: What Are 303(d) Impaired Waters?

A 303(d) listing means a waterbody has failed to meet its designated use standards even after technology-based pollution controls are applied. Designated uses define the intended purpose of a waterbody — for example: swimming (recreation), aquatic life, fish consumption, or drinking water supply.

Each waterbody is assessed at the level of an Assessment Unit (AU): a discrete, named segment of a waterbody with its own unique identifier. A single river may have multiple AUs assessed independently.

The assessment uses five categories:

Category Meaning
1 Fully supporting all designated uses
2 Attaining standards (minor concerns)
3 Insufficient information to assess
4A Impaired — TMDL completed and approved
4B Impaired — addressed through other control plans
4C Impaired by non-CWA pollutant (no TMDL required)
5 Impaired — TMDL needed (the “303(d) list” proper)

In this analysis, “impaired” includes all of Categories 4A, 4B, 4C, and 5 — waterbodies confirmed to be failing at least one designated use, regardless of whether a cleanup plan exists.

When a waterbody is listed as Category 5, DEP and EPA are legally required to develop and approve a TMDL. The TMDL process typically takes years to complete.


The count of impaired assessment units has grown in each reporting cycle, from 1,178 impaired AUs in 2010 to 1,564 in 2022, a 32.8% increase.

MA 303(d) Impaired Waters by Type

In physical terms, impaired river segments grew from 1,774 to 2,530 miles over this period (a 43% increase), and impaired lake area grew from 82,555 to 90,502 acres.

One question in interpreting this trend is whether the growth reflects actual deterioration or expanded assessment coverage — MA DEP assesses more waterbodies over time, which could mechanically increase the count. Looking at the persistence of existing listings helps address this. Of the 1,178 AUs impaired in 2010, 1,108 (94%) remained impaired through 2022. Only 70 (6%) were delisted over the twelve-year period. The overall growth in the list is primarily driven by the addition of newly assessed AUs rather than by recovery of previously listed ones.

The dominant water types are rivers and freshwater lakes, which together account for the majority of impaired AUs in every cycle. 573 impaired freshwater lakes and 366 impaired river AUs were present in 2010, growing to 648 and 620, respectively, in 2026. Estuaries are the third largest category — 239 impaired estuary AUs were recorded in 2010, growing to 296 in 2022. Rivers therefore had the greatest growth in recorded impaired AUs over this period.


How Many Impaired Waters Have Been Delisted?

Of the 1,178 waterbody segments listed as impaired in 2010, 1,098 appear as impaired in all six reporting cycles — continuously listed for at least twelve years. The chart below tracks that original 2010 cohort alongside AUs first listed in later cycles.

MA 303(d): Persistence of Impaired Waters

Over twelve years, 70 AUs were removed from the impaired list — 6% of those impaired in 2010. During the same period, 456 AUs were added.

The 70 AUs that left the impaired list fall into three categories based on their status in the 2022 data. Each is shown in a separate table below. Click any column header to sort.

43 AUs no longer appear in the 2022 assessment data at all. These may have been consolidated into differently numbered assessment units, removed from the assessment universe, or in some cases genuinely improved to the point of no longer requiring listing.

Removed from assessment entirely — 43 assessment units
Assessment UnitWaterbodyWatershedTypeSizeLast ListedCauses (2010)
MA51105 Mill Pond Blackstone Freshwater lake 12.0 acres 2014 Turbidity
MA51-10 Mill River Blackstone River 16.2 miles 2010 Aquatic Plants (Macrophytes); Non-Native Aquatic Plants; Other; PCB in Fish Tissue
MA95150 Tremont Mill Pond Buzzards Bay Freshwater lake 30.7 acres 2014 Non-Native Aquatic Plants
MA82096 Russell Millpond Concord Freshwater lake 32.9 acres 2014 Non-Native Aquatic Plants; Other flow regime alterations
MA82104 Stearns Mill Pond Concord Freshwater lake 19.1 acres 2014 Aquatic Plants (Macrophytes); Dissolved oxygen saturation; Excess Algal Growth; Non-Native Aquatic Plants; Phosphorus (Total); Turbidity
MA33-08 South River Deerfield River 13.0 miles 2014 Fecal Coliform; Physical substrate habitat alterations
MA21-16 Karner Brook Housatonic River 4.7 miles 2014 Low flow alterations
MA92031 Lower Boston Brook Pond Ipswich Freshwater lake 9.3 acres 2014 Non-Native Aquatic Plants
MA92035 Lubber Pond East Ipswich Freshwater lake 6.2 acres 2014 Non-Native Aquatic Plants; Sedimentation/Siltation
MA92036 Lubber Pond West Ipswich Freshwater lake 9.6 acres 2014 Non-Native Aquatic Plants; Sedimentation/Siltation
MA35-12 East Branch Tully River Millers River 10.0 miles 2014 PCB in Fish Tissue
MA71-04 Alewife Brook Mystic River 2.3 miles 2016 Copper; Debris/Floatables/Trash; Fecal Coliform; Foam/Flocs/Scum/Oil Slicks; Lead; Oxygen, Dissolved; Phosphorus (Total); Taste and Odor
MA71021 Judkins Pond Mystic Freshwater lake 2.8 acres 2010 Fecal Coliform; Oxygen, Dissolved; Phosphorus (Total)
MA71031 Mill Pond Mystic Freshwater lake 2.0 acres 2010 Fecal Coliform; Oxygen, Dissolved
MA53-04 Palmer River Narragansett Bay River 5.6 miles 2014 Fecal Coliform; Low flow alterations; Nutrient/Eutrophication Biological Indicators
MA81-61 Unnamed Tributary Nashua River 0.3 miles 2014 Escherichia coli
MA73002 Bird Pond Neponset Freshwater lake 20.4 acres 2010 PCB in Fish Tissue
MA73028 Manns Pond Neponset Freshwater lake 5.7 acres 2010 Non-Native Aquatic Plants; Turbidity
MA73044 Popes Pond Neponset Freshwater lake 6.0 acres 2010 Aquatic Plants (Macrophytes); Turbidity
MA93-17 Rockport Harbor No. Coastal Estuary 0.0 square miles 2010 Fecal Coliform
MA93-21 Salem Harbor No. Coastal Estuary 1.7 square miles 2010 Estuarine Bioassessments; Fecal Coliform
MA93-25 Salem Sound No. Coastal Estuary 8.0 square miles 2010 Fecal Coliform
MA91008 Lower Mill Pond Parker Freshwater lake 9.9 acres 2010 Aquatic Plants (Macrophytes); Excess Algal Growth; Non-Native Aquatic Plants
MA94006 Beaver Dam Pond S. Coastal Freshwater lake 29.2 acres 2016 Non-Native Aquatic Plants
MA94-23 Eel River S. Coastal River 3.9 miles 2014 Fish-Passage Barrier; Non-Native Aquatic Plants
MA94037 Forge Pond S. Coastal Freshwater lake 15.9 acres 2014 Chlorophyll-a; Debris/Floatables/Trash; Dissolved oxygen saturation; Excess Algal Growth; Fecal Coliform; Non-Native Aquatic Plants; Phosphorus (Total); Secchi disk transparency
MA94038 Foundry Pond S. Coastal Freshwater lake 7.2 acres 2016 Turbidity
MA83003 Butterfield Pond Shawsheen Freshwater lake 3.0 acres 2014 Aquatic Plants (Macrophytes); Turbidity
MA83-05 Elm Brook Shawsheen River 5.0 miles 2014 Fecal Coliform; Physical substrate habitat alterations; Turbidity
MA62029 Cabot Pond Taunton Freshwater lake 8.6 acres 2014 Dioxin (including 2,3,7,8-TCDD); Pentachlorophenol (PCP)
MA62063 East Freetown Pond Taunton Freshwater lake 11.1 acres 2018 Non-Native Aquatic Plants
MA62075 Fulton Pond Taunton Freshwater lake 9.3 acres 2014 Dioxin (including 2,3,7,8-TCDD); Pentachlorophenol (PCP)
MA62090 Hobart Pond Taunton Freshwater lake 9.0 acres 2014 Non-Native Aquatic Plants; Turbidity
MA62091 Hodges Pond Taunton Freshwater lake 7.0 acres 2014 Dioxin (including 2,3,7,8-TCDD); Pentachlorophenol (PCP)
MA62097 Johnson Pond Taunton Freshwater lake 13.5 acres 2016 Non-Native Aquatic Plants
MA62-39 Rumford River Taunton River 8.0 miles 2014 Aquatic Macroinvertebrate Bioassessments; Dioxin (including 2,3,7,8-TCDD); Fecal Coliform; Fishes Bioassessments; Pentachlorophenol (PCP); Physical substrate habitat alterations; Sedimentation/Siltation
MA62172 Shovelshop Pond Taunton Freshwater lake 7.0 acres 2014 Non-Native Aquatic Plants
MA62185 Sweets Pond Taunton Freshwater lake 13.5 acres 2014 Non-Native Aquatic Plants
MA62112 Vandys Pond Taunton Freshwater lake 8.6 acres 2014 Non-Native Aquatic Plants
MA62-49 Wading River Taunton River 9.7 miles 2014 Fecal Coliform
MA62228 Whittenton Impoundment Taunton Freshwater lake 20.0 acres 2014 Non-Native Aquatic Plants
MA32-23 Moose Meadow Brook Westfield River 8.2 miles 2014 Fecal Coliform; Turbidity
MA74028 Ice House Pond Weymouth & Weir Freshwater lake 0.6 acres 2010 Chlordane; DDT

18 AUs are now listed as Category 2 — meaning they are assessed as meeting water quality standards, though with some concern. This is the clearest indication of improvement among the three groups.

Now Category 2 (meeting standards) — 18 assessment units
Assessment UnitWaterbodyWatershedTypeSizeLast ListedCauses (2010)
MA95-66 Little River Buzzards Bay Estuary 0.2 square miles 2014 Nitrogen (Total)
MA96-69 Coonamessett River Cape Cod River 3.4 miles 2010 Nitrogen (Total)
MA96-47 Crows Pond Cape Cod Estuary 0.2 square miles 2010 Nitrogen (Total)
MA96324 Upper Mill Pond Cape Cod Freshwater lake 247.4 acres 2010 Excess Algal Growth; Oxygen, Dissolved; Phosphorus (Total); Turbidity
MA36-01 East Branch Ware River Chicopee River 12.4 miles 2016 Oxygen, Dissolved
MA36-27 Ware River Chicopee River 4.9 miles 2016 Oxygen, Dissolved; Temperature, water
MA11009 Mauserts Pond Hoosic Freshwater lake 50.9 acres 2014 Enterococcus
MA21-01 East Branch Housatonic River Housatonic River 11.3 miles 2016 Fecal Coliform; PCB in Fish Tissue
MA21-11 Wahconah Falls Brook Housatonic River 3.4 miles 2014 Fecal Coliform
MA92-10 Wills Brook Ipswich River 1.7 miles 2014 Fecal Coliform; Oxygen, Dissolved
MA97-27 Madaket Harbor Islands Estuary 1.4 square miles 2014 Fecal Coliform
MA97-20 Westend Pond Islands Estuary 0.1 square miles 2014 Fecal Coliform
MA73-12 Mill Brook Neponset River 3.1 miles 2010 Fecal Coliform
MA73-06 School Meadow Brook Neponset River 1.9 miles 2014 Fecal Coliform
MA73-17 Traphole Brook Neponset River 3.9 miles 2014 Fecal Coliform
MA93-45 Alewife Brook No. Coastal River 1.4 miles 2014 Fecal Coliform
MA94-24 Iron Mine Brook S. Coastal River 1.4 miles 2014 Fecal Coliform
MA32-05 Westfield River Westfield River 17.8 miles 2014 Aquatic Macroinvertebrate Bioassessments; Excess Algal Growth; Taste and Odor; Turbidity

9 AUs are now listed as Category 3 — insufficient data to make an assessment. These were removed from the impaired list not because of demonstrated improvement, but because current monitoring data is inadequate to support a listing decision.

Now Category 3 (insufficient data) — 9 assessment units
Assessment UnitWaterbodyWatershedTypeSizeLast ListedCauses (2010)
MA82129 Meadow Pond Concord Freshwater lake 12.4 acres 2016 Non-Native Aquatic Plants
MA34045 Loon Pond Connecticut Freshwater lake 25.1 acres 2014 Nutrient/Eutrophication Biological Indicators
MA33020 Tannery Pond Deerfield Freshwater lake 0.5 acres 2014 Low flow alterations
MA42037 New Pond French Freshwater lake 33.0 acres 2014 Aquatic Plants (Macrophytes)
MA42042 Peter Pond French Freshwater lake 42.0 acres 2014 Oxygen, Dissolved; Phosphorus (Total)
MA21110 Upper Goose Pond Housatonic Freshwater lake 55.3 acres 2016 Eurasian Water Milfoil, Myriophyllum spicatum
MA84A-19 Martins Pond Brook Merrimack River 2.3 miles 2010 Oxygen, Dissolved; Sedimentation/Siltation; Turbidity
MA35062 Ramsdall Pond Millers Freshwater lake 2.1 acres 2014 Aquatic Plants (Macrophytes)
MA93013 Cedar Pond No. Coastal Freshwater lake 34.0 acres 2016 Non-Native Aquatic Plants

What Is Causing Impairment?

The 2022 cycle identifies over 90 distinct causes of impairment across Massachusetts waterbodies. The most widespread are bacterial indicators — fecal coliform and E. coli — followed by dissolved oxygen, non-native aquatic plants, mercury in fish tissue, and nutrients.

Top Causes of MA Water Impairment (2022)

The chart below shows how the top causes have changed across all six reporting cycles. Several patterns are notable.

Fecal coliform has been consistently the most common cause throughout the period, but E. coli goes from essentially zero to ~300 AUs between the 2014 and 2016 cycles. This does not reflect a sudden biological event: E. coli replaced fecal coliform as EPA’s recommended bacterial indicator for primary contact recreation in EPA’s 2012 Recreational Water Quality Criteria. MA DEP incorporated E. coli assessment criteria into its 2016 Consolidated Assessment and Listing Methodology (CALM), which is why it appears in the 2016 reporting cycle data; the underlying Massachusetts surface water quality standards were formally amended in 2021. The two indicators largely measure the same contamination.

The 2016 cycle also sees dissolved oxygen, nutrient/eutrophication biological indicators, fanwort, and fish passage barriers all appear or increase sharply — several going from near-zero to hundreds of AUs. This reflects methodological and categorical changes in how MA DEP conducted and reported assessments that cycle, not five simultaneous environmental events. Most notably, fanwort was split out from the broader “non-native aquatic plants” category, which explains the corresponding decline in that count after 2016.

Mercury in fish tissue has increased gradually — from 158 AUs in 2010 to 204 in 2022 — as expanding fish tissue monitoring programs identify more affected waterbodies, though the rate of increase is slow and uneven. Fish passage barriers grew sharply from 18 AUs in 2016 to 112 in 2018, a pattern consistent with the methodological expansions that characterized that cycle rather than a sudden proliferation of physical barriers.

Top Impairment Causes Across Reporting Cycles

Bacterial contamination is the leading cause (355 AUs for Fecal Coliform, 324 AUs for Escherichia Coli (E. Coli)). Bacteria from human waste are the primary basis for beach and fishing closures, and can originate from combined sewer overflows (CSOs), sanitary sewer overflows, failing septic systems, and stormwater runoff. The source attribution data for bacterial impairments shows that MS4 municipal stormwater systems are the most commonly cited source, followed by CSOs and septic systems — though “Source Unknown” accounts for the largest share, reflecting the difficulty of attributing impairment to a specific discharge.

Sources of Bacterial Water Impairment (2022)

Swimming use. In 2022, 689 of the 1,062 assessed AUs — 65% — do not meet the Primary Contact Recreation standard, which is the threshold for safe swimming.

Dissolved oxygen impairment (273 AUs) is driven by excess nutrients (nitrogen and phosphorus), which fuel algal blooms. When algae decompose, the process consumes oxygen, reducing the dissolved oxygen available to aquatic life. Common nutrient sources include sewage effluent and agricultural and stormwater runoff from fertilized land.

Mercury in fish tissue reflects decades of atmospheric deposition from coal combustion and industrial emissions — a legacy problem that persists long after the original sources are controlled.

Non-native aquatic plants (particularly fanwort, Cabomba caroliniana) represent ecological impairment from invasive species rather than chemical pollution, and are widespread in Massachusetts lakes and ponds.


CSO Discharges and 303(d) Status

Combined sewer overflows (CSOs) are a distinct type of discharge from aging sewage infrastructure in urban areas: during heavy rain events, combined stormwater and sewage systems can overflow, releasing untreated wastewater directly to receiving waters. A natural question is whether these discharges occur in waterbodies that are already impaired under the 303(d) framework.

To examine this, we matched MA EEA Data Portal CSO discharge records — covering June 2022 through present — to 303(d) status for each receiving waterway using a manually verified mapping table. The mapping covers 39 of the 56 distinct CSO-reporting waterways in the EEA Data Portal.

The 17 waterways that could not be matched fall into two categories. Some use highly localized names — drainage channels, unnamed brooks, or facility-specific designations — that do not correspond to any named assessment unit in the 303(d) dataset. Others are reported with names that differ enough from the 303(d) assessment unit names (e.g. abbreviations, alternate spellings) that a reliable match could not be established without manual verification for each entry. These unmatched discharges are shown separately in the chart as “Status unknown (no 303d match)” — their impairment status is not known, not confirmed clean.

CSO Discharge Volume by 303(d) Impairment Status

Among the 39 matched waterways, all are rated “Not Supporting” in the most recent 303(d) cycle. Of the 20.2 billion gallons of total reported CSO discharge, 78.4% went to these confirmed-impaired waterways; the remaining 4.4 billion gallons discharged to waterways we could not match to a 303(d) record.

The chart below shows each group of waterways ranked by the fraction of their assessed AUs with bacterial impairment (fecal coliform or E. coli). Each red dot is one CSO-receiving waterway; hover for the waterway name and AU counts. The grey line shows all other 303(d) waterways.

Among non-CSO waterways, approximately 74% have zero assessed AUs with bacterial impairment. Among CSO-receiving waterways, most have 100% of their assessed AUs with bacterial impairment, and no waterway falls below 25%.

One question raised by this pattern is whether it reflects CSO outfalls specifically, or urbanization more broadly. The bar chart below shows the fraction of assessed AUs with bacterial impairment grouped by the predominant pollution source type attributed to each waterway by assessors. “CSO-receiving” uses the mapping table; all other groups exclude CSO-mapped waterways.

Bacterial Impairment Rate by Predominant Pollution Source (2022)

Waterways with CSO or MS4/urban stormwater attribution have the highest bacterial impairment rates (72% and 47% of assessed AUs respectively), followed by septic-influenced waterways (42%), agricultural waterways (32%), and others (30%). The gap between CSO and MS4 waterways is partly a function of selection: CSO-mapped waterways were specifically identified because they receive direct sewage discharges, while the MS4 group includes a broader mix of urban waterways. Impairment assessments reflect multiple pollution sources, and source attribution in the 303(d) data is often uncertain — “Source Unknown” is the most commonly recorded source overall.

This pattern reflects the geographic concentration of combined sewer infrastructure in older urban areas — the same watersheds where water quality impairment has historically been documented. The overlap does not by itself indicate that CSOs are the cause of the 303(d) listings, since impairment assessments reflect multiple pollution sources.


TMDL Progress

For every Category 5 impaired waterbody, MA DEP and EPA must develop a TMDL before further water quality improvements can be required. The chart below tracks the share of impaired AUs with and without a completed TMDL across reporting cycles.

MA 303(d): TMDL Progress Over Time

In 2010, 468 of 1,178 impaired AUs had a completed TMDL (39.7%). In 2022, 593 of 1,564 had one (37.9%). The number of AUs without a cleanup plan grew from 710 to 971 over the same period.

Averaged across reporting cycles, approximately 25 net new TMDLs have been completed per two-year cycle. At that pace, and assuming no new listings, the current backlog of 971 AUs without a plan would not be cleared until around 2100. (However, see the note at the top of this page about the new statewide TMDL.)

The chart below tracks what happened to the 710 AUs that were listed as Category 5 (TMDL needed, none yet) in 2010 — the earliest cycle in our data. Because 2010 is our starting point, the true wait for many of these AUs is longer than the chart shows; some had already been listed for years before 2010.

TMDL Progress for 2010 Category-5 Cohort (710 AUs)

By 2022, 85% of that original cohort — 602 AUs — still had no completed cleanup plan.

This pattern is not unique to Massachusetts. The National Academies has documented that approximately 21,000 polluted water segments nationally require over 40,000 TMDLs, and states consistently cite limited personnel and funding as constraints on completion.

As noted above, EPA’s April 2025 statewide pathogen TMDL for Massachusetts may change the picture for bacterial impairments specifically. By establishing load limits for all pathogen-impaired waters at once, it could formally satisfy the TMDL requirement for a large number of AUs — potentially shifting the fraction shown in future reporting cycles. The practical effect on water quality will depend on how the TMDL is implemented through individual permit requirements and infrastructure improvements.

The map below shows TMDL completion by watershed as of 2022. Circle size reflects the count of impaired AUs; color reflects the fraction with a completed TMDL (green ≥ 50%, orange 25–49%, red < 25%).


Watershed Breakdown

Impairment is not evenly distributed across the state. The watersheds with the most impaired AUs in 2022 include both heavily urbanized areas and coastal watersheds. The chart below breaks down impaired AUs by water type within each watershed.

MA Watersheds: Impaired Waters by Type (2022)

Cape Cod’s high count reflects its shallow, nutrient-sensitive coastal ponds and estuaries, where development pressure and aging septic systems have contributed to widespread nitrogen impairment. Buzzards Bay and the South Coastal watershed face similar conditions. The Taunton and Blackstone watersheds reflect more urban and industrial stressors.


Summary

The 303(d) Integrated List provides the most direct available measure of water quality conditions in Massachusetts waterbodies. Several patterns are visible in the data from 2010 through 2022:

  • The count of impaired AUs has grown in every reporting cycle, from 1,178 to 1,564. Most of this growth reflects newly assessed waterbodies rather than deterioration of previously passing ones, but it is also true that few AUs have been removed from assessment (whether because of improved water quality or for any other reason).

  • Bacterial contamination — fecal coliform and E. coli — is the most commonly cited cause of impairment, attributable to a mix of sources including stormwater, CSOs, and septic systems. 65% of assessed waterbodies do not meet the standard for safe swimming.

  • Among CSO-reporting waterways that could be matched to 303(d) records, all are classified as impaired in the 2022 cycle.

  • The fraction of impaired AUs with a completed TMDL has remained roughly flat at 38–40% across all six cycles, while the absolute number without a plan has grown. EPA’s April 2025 statewide pathogen TMDL changes this situation, though its water quality impact remains to be seen.


This post was prepared with assistance from Claude, an AI assistant, which helped structure the analysis, write code, and draft text. All data, text, methodology, and conclusions were reviewed and approved by the site author.