The Honorable Christine Barber, House Chair
The Honorable Rebecca Rausch, Senate Chair
Joint Committee on Environment and Natural Resources
State House, Boston

Delivered electronically

Dear Chair Barber, Chair Rausch, and Distinguished Members of the Committee,

On behalf of all 351 cities and towns across the Commonwealth, I write today to express our appreciation for your work and offer our strong support for H. 1039 and S. 675, An Act to assist municipal and district ratepayers.

Cities and towns are front-line environmental stewards, and this work must be done in strong partnership with the Commonwealth. We are extremely grateful for your continued support of cities and towns and the residents we collectively serve. We know that this important work with the Commonwealth is essential to continue to make progress toward our shared environmental goals today and in the coming years.

It’s with this vision in mind that we urge the Committee to support H. 1039 and S. 675, An Act to assist municipal and district ratepayers. Massachusetts is known for nurturing cutting-edge scientific study and using the data produced to guide our investments for the future. We are also known as leaders in policy that drive us toward noteworthy improvements to people’s lives and the planet. This reputation is achieved through careful data analysis, planning, and strategic deployment of resources for the best outcomes.

H. 1039 and S. 675 are an extension of these practices that make up a central component of good governance. This legislation would require the Massachusetts Executive Office of Energy and Environmental Affairs to complete a regulatory impact statement when proposing or releasing any rule, regulation, guidance document, or policy pertaining to water, wastewater, and stormwater. The bill would guarantee that state and local governments, as well as the general public, are fully informed of the full implications of the proposed environmental regulations.

Equipped with the data provided by the cost-benefit analysis, municipal and state governments can better allocate resources to guarantee that the goals of the regulation are within reach. This legislation would also protect local governments from unfunded mandates, an issue of top importance to our 351 municipalities.

Cities and towns throughout Massachusetts have made enormous investments in their water, wastewater, stormwater infrastructure and associated processes. Our local officials make these investments because these systems are essential to our environment, our economy, and our daily lives. Still, our communities are facing unprecedented expenditures to repair outdated infrastructure, expand infrastructure to allow for new housing and economic development, and address increasingly stringent environmental regulations that often require extensive training and additional staffing.

As you know, cities and towns are limited by Proposition 2½ in their ability to generate revenues. More and more communities are contending with structural deficits and attempting overrides and debt exclusions to ensure essential services are maintained and critical local infrastructure is in a state of good repair, including for water, wastewater, and stormwater projects. With these limitations, costs can often be passed on to ratepayers, further stressing the budgets of individuals and families.

Additionally, municipalities and their water and wastewater districts face increased regulations and associated costs for per- and polyfluoroalkyl substance (PFAS) remediation, combined and sanitary sewer overflow notifications, Municipal Separate Storm Sewer System (MS4) maintenance, and other new requirements. Finally, federal policy changes are still uncertain, including a proposal to significantly reduce federal investment in the State Revolving Fund — Massachusetts’ premiere program to fund water, sewer, and stormwater projects. In this policy landscape, any new regulations initiated by the state should be thoughtfully and thoroughly analyzed. A regulatory impact statement would provide a reasonable baseline measure of the cost-benefit tradeoff for all parties and provide a necessary reference to guide decisionmaking on regulatory boundaries and resource allocation.

We strongly urge the committee to support these bills and move them favorably out of committee.

Many thanks to each of you for your thoughtful consideration for this legislation and thank you for the opportunity to submit testimony on this important issue. If you have any questions or desire further information, please do not hesitate to have your office contact me or MMA Senior Legislative Analyst Adrienne Núñez at [email protected] at any time.

Thank you for your steady leadership, ongoing partnership with cities and towns, and commitment to the well-being of residents and the natural environment that supports us all.

Sincerely,

Adam Chapdelaine
MMA Executive Director and CEO

+
+