The Honorable Marjorie C. Decker, House Chair
The Honorable William J. Driscoll, Jr., Senate Chair
Joint Committee on Public Health
State House, Boston

Delivered electronically

Dear Chair Decker, Chair Driscoll, and Members of the Committee,

On behalf of the 351 cities and towns of the Commonwealth, the Massachusetts Municipal Association (MMA) writes to express its support for H. 2450 and S. 1504, An Act to Protect Massachusetts Public Health from PFAS.

As you know, per- and polyfluoroalkyl substances (PFAS) are a family of chemicals used since the 1950s to manufacture stain-resistant, water-resistant, and non-stick products. Also found in firefighting foam and other fire retardants, PFAS have been detected in water and soil sources in Massachusetts. Scientific studies have shown that exposure to some PFAS in the environment may be linked to harmful health effects in humans and animals. These so-called ‘forever chemicals’ persist for long periods of time in the environment and in various mediums. Remediation and decontamination efforts are therefore difficult and costly due to their chemical composition as well as the specificity of technology required to separate the substances from water, as one example.

Despite the challenges in responding to this history of ubiquitous pollution, it is essential that measures be taken to stop the continued use and release of these chemicals into our environment. Filed by Speaker Pro Tempore Kate Hogan and Senator Julian Cyr, this bill is a priority for MMA members, and we are grateful for their continued legislative leadership on this topic.

H. 2450 and S. 1504 encompass the recommendations of the PFAS Interagency Task Force, which studied this emerging issue for months to identify policy solutions relevant to the Commonwealth and its residents. This group brought together a large group of stakeholders, including municipal representatives from the MMA as well as public drinking and clean water professionals.

In January of 2025, the MMA’s membership adopted a Resolution Supporting a Local-State-Federal Partnership to Address PFAS Contamination, Fund Remediation, and Protect Public Health. This resolution reflected a slate of recommendations to support cities and towns, and through them their residents and visitors, in the important work to tackle PFAS in the myriad ways PFAS enters our local communities.

Critical to this resolution is the passage of the recommendations of the Task Force, including the discontinuation of the manufacturing and use of PFAS chemicals in all feasible applications and help to support and spur development of well-tested, safer alternatives to address PFAS pollution at the source.

Cities and towns have led the way to protect public health by implementing drinking water regulations and sharing information with residents. Massachusetts remains a national leader in addressing PFAS contamination in public water systems, and this legislation would further expand this action on PFAS across several other integral sectors.

We are grateful to the Legislature and the Governor for signing a law to implement one recommendation of the task force last year that requires manufacturers to disclose the inclusion of PFAS in firefighter turnout gear and banning the sale of turnout gear with PFAS starting in 2027. We support the provisions of H. 2450 and S. 1504 that would further prohibit intentionally added PFAS from being sold in consumer products and further regulate industrial release of PFAS.

However, it is imperative that any anti-pollution provisions within this legislation do not impose any impossible requirements on municipalities. We echo the comments of the Massachusetts Water Works Association (MWWA) and the Massachusetts Coalition for Water Resources Stewardship (MCWRS) regarding wastewater. There must be feasible, trustworthy solutions before any requirements are imposed on permits of municipal water systems or wastewater discharges. The U.S. EPA has not yet identified effective solutions to treat wastewater for PFAS, and existing treatment technologies for drinking water are not applicable to wastewater. We have similar concerns on the sections impacting the land application of sludge. Municipal wastewater and drinking water treatment processes can generate sludge, and local governments and water districts are experiencing increasingly extreme costs to dispose of sludge. It’s important to note that banning land application of sludge or enforcing certain limitations with no feasible alternative is not a recommended solution at this time. We appreciate your consideration as the Committee investigates preferred language for this important issue in the bills.

Additionally, the provision of safe drinking water remains a priority of local governments and their public water systems. This legislation would further support this essential public service by creating a PFAS Remediation Trust Fund to finance costs currently being incurred by local governments with state funding, litigation settlements, and other sources.

Municipalities currently subject to the Massachusetts regulatory framework for PFAS have invested significant expense in complying with this public drinking water system standard. The maximum contaminant levels (MCLs) for a summary of six PFAS chemicals is 20 parts per trillion, or ppt. For a community with test results over 20 ppt for these chemicals, remediation can cost millions of dollars.

Financial support for critical water infrastructure was already desperately needed in Massachusetts. The U.S. EPA’s most recent estimate for the Commonwealth’s needs for drinking water infrastructure, in particular, came in at $15 billion over the next 20 years. It’s important to note that this estimate (the 7th Drinking Water Infrastructure Needs Survey and Assessment) did not incorporate financial needs to comply with PFAS standards and regulations.

The United States Environmental Protection Agency (U.S. EPA) drinking water regulations will also place significant financial strain on our membership. This is one of many reasons why financial support and resources for municipal governments and their water districts is essential. The trust fund would complement existing programs and help the state identify the true need of public water systems as the regulatory landscape for PFAS chemicals develops amid growing federal funding uncertainty.

In summary, this legislation would be incredibly valuable to cities and towns and would bring significant public health benefits to the entire Commonwealth. However, any provisions impacting municipal governments and water systems must be practical to implement. We are grateful for your work on this important issue, and we appreciate your consideration of these comments on behalf of local government.

If you have any questions or desire further information, please do not hesitate to have your office contact me or MMA Senior Legislative Analyst Josie Ahlberg at any time.

Sincerely,

Adam Chapdelaine
MMA Executive Director & CEO

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