Gardner Landfill

Opposing the Proposed Gardner Sludge Landfill Expansion:

A Healthy Vision for our Watershed

Welcome! The Millers River Watershed Council (MRWC) is opposing this ill-conceived project, which will, if approved, have substantial negative consequences for our region and beyond. The area of the proposed project expansion is within 1,300 feet of the Otter River and contains several vernal pools certified by MRWC.

MRWC has been working for several years with residents of Gardner to urge the City to adopt a cleaner, safer and more economically sensible solution to managing its sludge waste. Besides the adverse impacts the project would cause on the local and regional environment, we believe that approval of this project would send the wrong message to communities and stakeholders state-wide about the future of wastewater solids management throughout the State. We don’t believe the Chair City’s legacy is to become Dump City for the rest of the Commonwealth.

On this page you will find:

  • Project Map: 1-mile radius
  • Update: Victory for Vernal Pools in Gardner, March 2021
  • Detailed Project Information
  • Future updates will provide information on other actions you can take to support this work.
  • last update 5/1/21


At the Gardner Conservation Commission’s meeting on March 8, 2021, the Commission voted unanimously for a positive determination of applicability on the three certified vernal pools under the Gardner Wetland Protection Ordinance. The vernal pools are located in located in the Wildwood Cemetery Forest and Cummings Otter River Conservation Area. This finding was in response to a Request for Determination of Applicability (RDOA) filed on December 16, 2020 by Ivan Ussach (MRWC Director) on behalf of MRWC and Alan Rousseau (property abutter).  Matt Marro (Environmental Consultant) did a great job in presenting our position and addressing questions on vernal pool #3’s location that arose at the 1/25/21 meeting.  In addition, Nathaniel Stevens, Esq. (McGregor & Legere, P.C.) attended the meeting in order to provide legal support. The RDOA was seeking a determination that the three state-certified vernal pools are subject to the jurisdiction of the Gardner Wetland Protection Ordinance.   Recognition of these state-certified vernal pools is important, considering that the City of Gardner has been proposing a large expansion of the sludge landfill in the Wildwood Cemetery Forest.

We thank the many concerned local citizens who attended these meetings in support of a positive determination



The City of Gardner proposes a major expansion of the Sludge Landfill on the almost 200-acre Wildwood Cemetery Forest property, located at 850 West Street in Gardner MA. The property abuts the city-owned 122-acre Cummings Otter River Conservation Area (established in 2012). The property also abuts a 69-acre privately owned property enrolled in Chapter 61 (Forestry) and is within 1⁄2 mile of the newly acquired North County Land Trust’s 157-acre Ebenezer Keyes Conservation Area.

The Wildwood Cemetery Forest is a 189-acre city-owned property that includes 119 acres of undeveloped forest and wetlands, including a large intact esker, two certified vernal pools, a kettle-hole level bog, and hiking trails. Over the years, this property has undergone some development on 70 acres including a 23-acre closed (and capped) Solid Waste Landfill & recycling / trash transfer station, a 22-acre large scale photovoltaic solar array, the 13-acre Wildwood Cemetery, and the 12-acre Sludge Landfill.The expansion is planned for approximately 8-10 acres of undeveloped land to the west of the existing sludge landfill. To date, the City as invested about $640,000 in engineering and planning for the expansion.

II. Objections to the landfill expansion include:

    1.     Risk of future ground water contamination with potential impact to drinking water. Approximately 60 private residential wells and the Templeton Otter River Town Well are within a 1-mile radius. The abutting 69-acre Rousseau property has two spring fed ponds and a private well. The entire area of the Wildwood Cemetery Forest, Cummings Conservation Area, and Rousseau property has many wetlands, drains via Bailey Brook (a cold water fishery) to the Otter River—the largest tributary to the Millers River.

    2.     Destruction of 8-10 acres of natural resources in the Wildwood Cemetery Forest, including wildlife habitat, forest, natural esker, and certified vernal pools.

    3.     Continued source of ongoing strong sewer-type odors as evidenced by many years of odor complaints originating from the existing landfill by residents of Gardner and Templeton.

    4.     Negative impacts to public’s recreational use and enjoyment of the abutting 122-acre Cummings Otter River Conservation Area established by the City in 2012 with $402,000 of state and federal Funding. Likely negative impacts include odors and the unsightly view of sludge landfill itself right at the Cummings property line.

    5.     Failure of the City to present a thorough and accurate examination of the various sludge management options and their costs.

III. Project Alternatives Exist

There are many feasible alternatives to the Sludge Landfill Expansion, including recycling to soils (composting, fertilizer), hauling out for Incineration, and Anaerobic Digestion (AD). Currently, AD seems to offer the best choice for an alternative that is a cost effective and environmentally friendly, with the added benefit of being consistent with Massachusetts’ goals for renewal energy. In 2015, a CDR Maguire consultant created an alternatives analysis for the City. However, this consultant had previously worked on the expansion planning (as early as 2012) and now is the project manager for the expansion project. The City needs to initiate an independent feasibility study to explore AD options. 

IV. Opposition strategy:

In 2020, MRWC and an abutter (A. Rousseau) hired the prestigious Boston-based environmental law firm of McGregor and Legere PC for legal services and Matthew S. Marro Environmental Consulting for environmental services. We are challenging the proposed expansion on several legal and regulatory fronts, as well as working to muster public opposition through various means.  

V. Chronology of Major Events:

1985 – City receives site assignment approval for existing Sludge Landfill

1990 – Operations begin at existing Sludge Landfill

2005 – Solid Waste Landfill Closes – Also emits terrible odors for 2-3 years after capping

2012 – CDR Maguire begins evaluations for Sludge Landfill expansion

2012 – Cummings Otter River Conservation Area is established by the City of Gardner with state and federal grants.

2013 – Sludge Landfill reaches maximum capacity per design specifications.

2014 – Major odor problems reported by residents results in a Board of Health Public Meeting at which the Board Chair commits to further discussion and action as covered by local newspaper articles.

2014 – Gardner Clear Air grassroots group is founded and advocates for alternative solution to expansion.

2015 – United Water (landfill operator) implements work procedure changes to reduce odors. Odors reduced, but continue to the present time.

2015 – CDR Maguire consultant prepares alternatives analysis for sludge disposal and concludes Sludge Landfill expansion is determined to be lowest cost option.

2016 (Feb) – MADEP approves 30-foot vertical expansion of existing Sludge Landfill.

2016 (Nov) – Gardner Clean Air partners with the Millers River Watershed Council (MRWC).

2016 (Dec) – After a well-attended City Council public hearing in October, in which not a single person spoke in favor of the project (except for the Mayor), and during which Gardner Clean Air submitted a petition with over 300 signatures of residents opposing the project, the City Council approves the Mayor’s order to endorse the Sludge Landfill expansion.

2017 (Oct) – City submits initial application for expansion, DEP advises that a different application for required. 2018 (May) — DEP & City execute Individual Project Rule.

2019 – MRWC certifies three vernal pools with NHESP. NHESP notifies Gardner Conservation Commission of certification.

2020 (Feb) – DEP & City Meeting on expansion.

2020 (Jun) – Gardner Conservation Commission issues Order of Resource Area Delineation (ORAD) confirming the accuracy of the boundaries of the bordering vegetated wetlands and vernal pool (identified as B series) under the MA Wetlands Protection Act.

2020 (Jun) – Abutter Alan Rousseau files appeal to ORAD

2020 (Jul) — During MADEP field visit to review wetlands delineation, City learns of certified vernal pools within and near proposed expansion area. MADEP requests that City provide water resource calculations for the vernal pools.

2020 (Aug) — City informs MADEP of inability to provide the requested information due to recent special election for a new Mayor and budgetary constraints.

2020 (Dec) – MRWC and Alan Rousseau (abutter) jointly file a Request for Determination of Applicability (RDA) under the Gardner Wetland Protection Ordinance to have the Conservation Commission recognize the certified Vernal Pools and confirm that work near them requires Conservation Commission approval.

2020 (Dec) – North County Land Trust (NCLT) acquires the 157-acre Ebenezer Keyes Conservation Area in order to establish a new conservation area in Gardner. This property is in the 1⁄2 to 1 mile radius of the proposed expansion.

2021 (Mar) – Gardner Conservation Commission votes unanimously for a positive determination on the Request for Determination of Applicability. This is a great victory for protecting the 3 vernal pools!