MMA letter to conference committee on recycling legislation

The Hon. Anne Gobi, Senate Chair
The Hon. William Smitty Pignatelli, House Chair
Joint Committee on Environment, Natural Resources and Agriculture
State House, Boston
 
Dear Senator Gobi, Representative Pignatelli, and Distinguished Committee Members,
 
On behalf of the cities and towns of the Commonwealth, the Massachusetts Municipal Association is writing to offer comments on several of the bills before the Committee today. As stewards of the environment, issues of solid waste and recycling are very important to municipal officials and residents in our communities.
 
Municipalities are on the front lines of environmental protection, and municipal leaders take this responsibility seriously. Local officials volunteer to serve on conservation commissions, boards of health, drinking water boards and sewer boards. Cities and towns across the Commonwealth have made enormous progress in reducing solid waste and increasing recycling programs. Most communities have built recycling and reuse facilities and many now include composting. Communities have also implemented automated curbside pickup and instituted unit-based pricing for waste collection, commonly known as “pay-as-you-throw,” to incentivize recycling. In fact, 90 percent of Massachusetts’s municipalities now provide comprehensive recycling programs for their residents.
 
The MMA supports S. 416, A Resolve Providing for an Investigation and Study of Enhancing Statewide Recycling Programs. This bill would study recycling and municipal solid waste programs to increase effectiveness in a way that makes sense for cities and towns. Municipalities have made enormous progress in reducing solid waste and increasing recycling throughout the state, but need additional tools, technical assistance and funding in order to increase recycling rates even more.
 
In addition to increasing resources for municipalities, the MMA and local officials have also long supported, and will continue to support, producer responsibility legislation to reduce solid waste at its source. Removing materials at the beginning of the use cycle is far more effective than mandating that taxpayers deal with the problem at end of the waste stream. We look forward to working with the Committee on this more preferable, cost-effective and environmentally beneficial approach.
 
Unfortunately, several of the bills before the Committee today would impose costly mandates on cities and towns to meet waste reduction targets and increase the administrative burden on municipalities through new requirements. The MMA opposes H. 2916/S. 475, An Act Relative to Recycling and H. 2917, An Act Establishing a Special Commission on Municipal Solid Waste. These bills would place a new mandate on cities and towns, primarily by imposing a set of solid waste “performance standards” on communities and instituting new annual reporting requirements. We have similar concerns about H. 430/S. 449, An Act to Reduce Solid Waste, Increase Recycling and Generate Municipal Cost Savings, although these bill would allow for more input from communities through the Solid Waste Advisory Committee.
 
These bills would direct the Department of Environmental Protection to establish performance standards for the reduction of municipal solid waste and would require municipalities to report information on solid waste disposal annually. Based on current estimates, 75% of communities exceed the 2022 performance standard of not more than 450 pounds per capita laid out in S. 475 and H. 2916, which means this costly unfunded mandate would impact cities and towns in every part of Massachusetts. Some of these bills would create a solid waste reduction assistance fund, but we are concerned that the fund would not be able to provide any significant assistance to cities and towns because there is no reliable revenue stream to support it.
 
Several other bills before the Committee would also reduce management flexibility for cities and towns the areas of solid waste and recycling, and would impose unworkable one-size-fits-all policies. The MMA opposes H. 414, An Act to Increase Access to Recycling and H. 2944/S. 439, An Act Relative to Solid Waste Practices. Local officials know their communities best, and the requirements imposed by these bills would require municipalities to implement specific types of recycling programs, rather than allowing local officials to shape programs that work best for their own communities.
 
It is important to recognize that cities and towns are already working hard as stewards of the environment. The above-referenced legislation would establish requirements that are unrealistic and unaffordable for many cities and towns, while undermining local flexibility. In order to increase recycling rates and reduce solid waste, municipalities need the flexibility to determine what system is best for their particular community and should receive adequate funding from the state to institute comprehensive programs.
 
Thank you for your consideration. We look forward to working with the Committee on effective, affordable and sustainable ways of reducing solid waste in Massachusetts. If you have any questions, or desire further information, please do not hesitate to have your office contact me or Victoria Sclafani of the MMA staff at (617) 426-7272 at any time.
 
Thank you very much.
 
Sincerely,
 
Geoffrey C. Beckwith
Executive Director & CEO