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

Delivered electronically

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

On behalf of cities and towns across the Commonwealth, the Massachusetts Municipal Association would like to offer its support for several bills at today’s hearing of the Joint Committee on Environment and Natural Resources. As communities continue to experience the direct threat of climate change and step forward to accelerate our state’s transition to a sustainable future, we recognize the need to view new environmental policies through a lens that will fully and transparently outline the costs and benefits of proposed regulations.

The MMA strongly supports H. 892 and S. 589, An Act to assist municipal and district ratepayers. The legislation specifically addresses new environmental regulations that pertain to water, wastewater, and stormwater. By requiring 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.

Simply put, this legislation is good governance. 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 and unfunded local mandates are avoided.

Cities and towns throughout Massachusetts have made enormous investments in their water, wastewater and drainage management processes and infrastructure. Local officials have done so 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 Still, our communities are facing unprecedented expenditures to repair outdated infrastructure, expand infrastructure to allow for new housing and economic development, and address increasingly stringent environmental regulations that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. All of these costs are then passed along to ratepayers, further stressing the budgets of individuals and families.

During a time when municipalities and their water and wastewater districts face increased regulations and associated costs for PFAS remediation, combined sewer overflow notifications, Municipal Separate Stormwater System maintenance, and other new requirements, new regulations initiated by the state should be thoroughly analyzed. A regulatory impact statement would provide a reasonable baseline measure of the cost-benefit tradeoff for all parties.

We would also like to note our support for another piece of legislation currently before the Committee, H. 852, An Act relative to municipal assistance for clean water and economic development infrastructure. This bill would create a Water Infrastructure Improvement Fund to provide for clean drinking water initiatives, address lead service line pipes, and make key improvements to wastewater and stormwater infrastructure. With funds allocated to each city and town through a carefully crafted formula, this capital outlay program would further complement the existing funding structures critical to the health and wellbeing of the Commonwealth. This bill centers municipalities at the heart of this work and aligns well with H. 892 and S. 589 to provide a dedicated revenue stream for communities to address rising costs for water, wastewater, and stormwater projects.

We appreciate the opportunity to submit testimony on this important issue and encourage the Committee to support these bills with a favorable report. If you have any questions or desire further information, please do not hesitate to have your office contact me or MMA Legislative Analyst Adrienne Núñez at anunez@mma.org at any time.

Thank you for your thoughtful consideration of this issue and your commitment to thriving cities, towns and surrounding natural environments.

Sincerely,

Geoffrey C. Beckwith
MMA Executive Director & CEO

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