Stephanie Pollack
Secretary of Transportation
Massachusetts Department of Transportation
10 Park Plaza, Suite 4160
Boston, MA 02116
Re: 2020-2024 Capital Improvement Plan (CIP)

Dear Secretary Pollack,
Thank you for considering these comments offered on behalf of the cities and towns of Massachusetts regarding the draft FY 2020-2024 MassDOT Capital Investment Plan. As we address the effects and risks from climate change, and manage competing local needs with limited financial resources, the MMA and our member municipalities are grateful for our continued partnership with MassDOT.

The MMA is a long-time advocate for increased funding to the Chapter 90 program. Much to the frustration of the MMA and our member municipalities, the bond authorization for this vital program has remained flat at $200 million over the last several years, and has not increased with inflation. Although the Legislature approves the final Chapter 90 authorization amount, the Administration and MassDOT have the authority to recommend a higher Chapter 90 bond authorization in the CIP and in their annual legislative filing. We respectfully ask that MassDOT consider a Chapter 90 recommendation of at least $300 million per year, indexed to inflation, for inclusion in the 2020-2024 CIP.

A detailed analysis conducted by the MMA in 2018 documented that our cities and towns need $685 million annually to maintain 30,000 miles of local roads in a state of good repair. Currently, municipalities spend far less because of inadequate resources and because, for most cities and towns, Chapter 90 is the main or sole source of funds for local road construction and repair. A $300 million authorization would enable cities and towns to begin to properly enact local road improvement plans and pursue a state of good repair that is a best practice standard for maintaining capital assets.

Our member municipalities greatly appreciate the funding and technical assistance provided for through MassDOT’s Complete Streets and Small Bridges programs. The MMA is pleased that MassDOT has continued to fund these municipal initiatives in the 2020-2024 CIP. The MMA, through its participation in the Small Bridge and Culvert Working Group convened by the Legislature and co-chaired by MassDOT and the Department of Fish and Game, is also aware of the underfunding of culvert repair and replacement projects. Among other recommendations, the Working Group is calling for MassDOT to increase direct funding and technical assistance for culverts (under 10 feet in diameter) and begin to address the backlog of needs.

Because Chapter 90 has been flatlined since fiscal 2012 (with exceptions in fiscal 2015 and 2019), inflation has dramatically reduced the value of state funding for local roads. Based on the analysis below (using U.S. DOT’s National Highway Construction Cost Index), the $200 million fiscal 2020 Chapter 90 bond authorization that has reached the Governor’s desk has lost over $50 million in value (25.44%) compared to fiscal 2012. The real (inflation-adjusted) value of Chapter 90 aid has declined dramatically.

Another factor to take into consideration is the decline of Chapter 90 within MassDOT’s own Capital Investment Plan. Between fiscal 2017 and 2019, MassDOT CIP’s share under the state bond cap has grown from $816 million to $953 million, an increase of 16.8%. Chapter 90 has remained fixed at $200 million, and has fallen from 24.5% to 21% of MassDOT’s CIP. At the very least, in order to provide stability and guard against the erosive impact of inflation, MassDOT’s should increase the Chapter 90 allowance to track its own CIP growth. A 16.8% increase in Chapter 90 from fiscal 2017 to 2019 would have lifted Chapter 90 to $233.6 million. While we are respectfully requesting that Chapter 90 be increased to $300 million a year, with annual inflation adjustments going forward, at a minimum we believe that MassDOT’s CIP should increase Chapter 90 to match the CIP’s growth. If this does not happen, then it would be reasonable to conclude that the Department is making an explicit decision to move cities, towns and local roads further down on the state’s priority list.

Thank you for your consideration of our suggestions and concerns as the CIP is finalized. If you have any questions, please do not hesitate to have your staff contact me or MMA Legislative Analyst Ariela Lovett at 617-426-7272 at any time.

Sincerely,

Geoffrey C. Beckwith
Executive Director & CEO