This week, MCWRS submitted a comment letter to the Co-Chairs of the Joint Committee on Environment, Natural Resources and Agriculture (JENRA) expressing our support of Bill H.4254 – An Act to enable the Commonwealth’s administration of the Massachusetts Pollution Discharge Elimination System. This legislation would begin the process to have the Massachusetts Department of Environmental Protection (MassDEP) seek delegation of the National Pollutant Discharge Elimination System (NPDES) permitting authority for the Commonwealth. Currently, the US Environmental Protection Agency (EPA) administers the program in Massachusetts, while 46 (soon to be 47) other states manage their own NPDES permitting. We have been tracking this legislation and advocating for primacy in recent blog posts and since our 2007 White Paper. Our letter includes references to our Primacy Position Paper and testimony from MCWRS President and Chairman, Phil Guerin, at the May 17 legislative hearing.
As of yesterday morning, JENRA has filed an extension order with a new reporting date of Thursday, June 30. That means there’s still time for all MCWRS members and other supporters of Bill H.4254 to fill in the blanks in this template letter and submit it to the JENRA Committee Co-Chairs and their Representatives or Senators! Find contact information, including email addresses, for your legislators and the JENRA Committee members.
Both the Coalition’s and the template letters highlight some key points we hope our elected officials consider before they cast their votes:
- Voting to delegate authority to MassDEP does not remove EPA from the permit process.
- MassDEP already has delegated authority for drinking water, air quality, and other programs that it is managing with great success.
- EPA’s one-size-fits-all approach to permitting does not consider location-specific environmental, social, and economic factors, whereas MassDEP is more familiar and in tune with the various regions, watersheds, and ecosystems in Massachusetts. Its water quality standards would be more site-specific and based on current scientific knowledge.
- MassDEP management of the program would provide greater opportunity for municipalities to successfully implement integrated water resources planning and address multiple regulatory requirements and community infrastructure needs, all while maintaining affordable water and sewer rates.
- Having MassDEP manage the program would ensure consistency with other state-run environmental initiatives.
- MassDEP Commissioner Martin Suuberg has identified the resources needed to successfully run the NPDES program and has committed $4.7 million annually to do so.
- MassDEP will manage NPDES permitting much more effectively and efficiently and produce a balanced program that protects the environment in an economically sustainable way.
We encourage our members to share a copy of their comments. This is a critically important opportunity for MCWRS to demonstrate our strength in numbers and leverage our impact!