Joint Committee on Environment, Natural Resources and Agriculture
State House, Boston

Dear Chair Pignatelli, Chair Gobi, and Distinguished Committee Members,

On behalf of the cities and towns of the Commonwealth, the Massachusetts Municipal Association appreciates the opportunity to provide input on the urgent need to address the significant solid waste and recycling challenges facing our communities and state, including comments on a number of measures that are pending before your committee. In a January 2019 resolution unanimously adopted at the MMA’s Annual Business Meeting by cities and towns across the state, the MMA and municipalities affirmed our commitment to working in partnership with the Legislature, the Administration, and the private sector to address the challenges associated with managing solid waste and recycling across Massachusetts.

As is now well-known, the upheaval in the global recycling marketplace over the past few years has directly impacted communities across the United States, hitting Massachusetts cities and towns particularly hard. Local governments have seen significant increases to the cost of their solid waste and recycling contracts, threatening the financial sustainability of waste and recycling management in our state. In providing this basic and essential service to residents and businesses, local government has shouldered a substantial financial and operational burden. Managing the safe and environmentally sound disposal and recycling of bulky and hazardous materials is a complex and costly process, especially for resource-challenged towns and cities.

In light of this reality, and in line with the policies and commitments named in the 2019 recycling resolution, the MMA strongly supports product stewardship legislation that requires producer or manufacturer responsibility over end-of-life management of mattresses, paint, and electronics (H.765/S.495; H.796; and S.532, respectively). The MMA also firmly believes that the status quo model for managing solid waste and recycling must shift toward increased producer responsibility over the collection, disposal or recycling of packaging and similar materials categories. Extended producer responsibility (EPR) will support the Commonwealth’s ongoing waste reduction efforts and will alleviate some of the cost and materials burden from local governments. The MMA has engaged our member local officials on the EPR packaging bills before your committee (H.745 and H.750), meeting with the advocates via our Policy Committee on Energy and the Environment, and participating in an EPR summit last spring. We encourage your committee and your colleagues in the General Court to seriously explore these alternative models for managing waste, and include consideration of these policy options in your deliberations to move the Commonwealth forward on this issue.

Over the past year and a half, the MMA has participated in meetings and discussions to inform the development of MassDEP’s new 10-year Solid Waste Master Plan. We believe it is critical for any legislation advanced by your committee to be integrated with the policy approach, waste reduction, diversion targets, and other commitments outlined in the final version of the Master Plan that is promulgated.

The MMA has important concerns about legislation before your committee that would require municipalities to meet specific performance targets for waste reduction and comply with strict reporting requirements. The MMA agrees that there is value in collecting more data about residential and commercial solid waste and recycling, and in setting and working to meet waste reduction and related goals. However, we believe it is premature to codify these goals or requirements in statute while the recycling marketplace is still in flux, before the Solid Waste Master Plan is finalized, or while state policies regarding product stewardship and source and packaging reduction are unknown.

Municipalities have been essential partners with the state in meeting waste reduction goals, by investing in diversion programs such as for textiles and organic materials, passing more than 100 local bylaws and ordinances banning plastic bags and other single-use plastic, and cleaning up residential recycling streams to reduce contamination. Until there is more consensus over how best to manage the disposal and recycling of our material waste, whether and what to ban from our waste stream altogether, and who should bear the costs, we remain strongly skeptical about codifying municipal performance targets and reporting requirements in statute. The feasibility and achievability of mandated goals and targets cannot be determined without a restored recycling marketplace, and without knowledge of the state assistance and coordinated policies that will be in place. Passage of economically infeasible or unaffordable mandates, no matter how worthy the intention, would have seriously negative consequences on other vital public services at the local level.

Thank you very much for the opportunity to comment on the solid waste and recycling bills being considered by your committee. We strongly encourage the committee to report out legislation that will improve our solid waste and recycling systems to reduce unnecessary waste and protect our natural environment, better manage materials, and alleviate costs for municipalities. If you have any questions, or desire further information, please do not hesitate to have your office contact me or MMA Legislative Analyst Ariela Lovett at 617-426-7272 or alovett@mma.org at any time.

Thank you very much.

Sincerely,

Geoffrey C. Beckwith
MMA Executive Director & CEO