Advocacy

Board members photoAdvocacy raises awareness among legislators, regulators and the public about issues of concern to MCWRS and its members. Comment letters and OpEd pieces are just a few of the ways MCWRS advocates for modifications to policies and regulations that make them more affordable and sustainable for communities. Members get the added benefit of having MCWRS submit comments on regulations affecting their facilities.

MCWRS has been involved with advocacy for issues related to:

Drinking Water
Stormwater
Wastewater
Other

Drinking Water

Comment letter to MassDEP supporting the Massachusetts Water Works Association’s comments regarding the proposed revisions to Drinking Water Regulations, 310 CMR 22.00.

Comment Letter to MassDEP Supporting MWWA

MWWA Comment Letter

Letter to MassDEP requesting the agency withdraw proposed revisions to Water Management Act (WMA) regulations.

MCWRS letter to MassDEP

Joint Letter to Governor Patrick from MWWA, MCWRS and MWPCA regarding concerns about SWMI regulations, including safe yield.

Letter to Governor Patrick

Environmental Protection Agency’s (EPA) response to comments on the National Pollutant Discharge Elimination System (NPDES) Draft General Permits for Discharges from Potable Water Treatment Facilities (PWTFs) for Massachusetts and New Hampshire

EPA’s Response to Comments
EPA NPDES Draft General Permit for Discharges from PWTFs
Attachment A: Re-evaluation of Discharge Monitoring Report Aluminum Data

Letter to MA Governor Patrick endorsing Toward Financial Sustainability, the Initial Report of the Water Infrastructure Finance Commission (WIFC)

MCWRS Letter to MA Governor Patrick
MA WIFC Letter to MA Governor Patrick presenting Initial Report: Toward Financial Sustainability
MA WIFC Initial Report: Toward Financial Sustainability

Letter to US Senator Brown urging support for US Senate Bill 3481, a bill to amend the Federal Water Pollution Act to clarify Federal responsibility for storm water pollution.

Letter to Senator Scott Brown
US Senate Bill 3481

Comment Letter in response to the Environmental Protection Agency’s (EPA) National Pollutant Discharge Elimination System (NPDES) Draft Massachusetts North Coastal Small Municipal Separate Storm Sewer Systems (MS4) General Permit.

Comment Letter to EPA Region 1

Comment letter in response to Environmental Protection Agency’s (EPA) National Pollutant Discharge Elimination System (NPDES) Draft General Permit for Residually Designated Discharges in Milford, Bellingham, and Franklin Massachusetts.

Comment Letter to EPA Region 1
EPA NPDES Draft General Permit for Residually Designated Discharges in Milford, Bellingham, and Franklin

Comment Letter on Charles River Watershed Association (CRWA) Draft Total Maximum Daily Load (TMDL) for Nutrients in the Upper/Middle Charles River, Massachusetts

Comment Letter on CRWA Draft TMDL for Nutrients in the Upper/Middle Charles River

Letter to US Senator Kerry regarding the Environmental Protection Agency’s (EPA) Enforcement Actions against 9 New England Communities

Letter to US Senator Kerry
EPA Press Release: Nine Mass. and N.H. Communities Face Actions to Improve Storm Sewer Pollution
Winthrop Transcript: Meeting with EPA is in order
Winthrop Transcript: EPA, town at odds over $70,000 fine
Concord Journal: Concord to appeal EPA storm sewer management complaint
Eagle Tribune: Plaistow faces $40,000 EPA fine

Comment Letter to Environmental Protection Agency (EPA) in response to Draft Handbook for Developing Watershed Total Maximum Daily Loads (TMDLs)

Comment Letter to EPA

Stormwater

Press release announcing EPA’s one-year postponement of the effective date for the Final Massachusetts Small Municipal Separate Storm Sewer General Permit (MS4) based on MCWRS’s request for a stay.

Press Release for Postponement of the MS4 Permit

Press release announcing MCWRS jointly filing a Petition for Review of the Final Massachusetts Small Municipal Separate Storm Sewer General Permit (MS4) in the First Circuit of the United States Court of Appeals in Boston with the Town of Franklin.

Press Release for MCWRS Appeal of MS4 Permit

Comment letter to EPA on the Draft Massachusetts Small MS4 General Permit, which is unreasonable, does not consider municipal realities, and is a regulatory over-reach by EPA.

Comment Letter to EPA

Comments on the New Hampshire Small MS4 draft general permit, the requirements of which MCWRS considers burdensome, with unreasonable schedules and deadlines and a TMDL mandate that is inconsistent with Clean Water Act provisions. Since New Hampshire’s permit could also become the Massachusetts permit, MCWRS considered it important to submit comments.

Comment Letter to EPA

Letter to MA Attorney General Coakley opposing the proposed MA Petition Initiative 11-10 capping annual water and sewer rate increases to 2.5%

Letter to MA Attorney General Coakley
MA Petition Initiative 11-10 Information Sheet
MA Petition Initiative 11-10 Summary

Comment letter in response to the Environmental Protection Agency’s (EPA) National Pollutant Discharge Elimination System (NPDES) Draft Massachusetts North Coastal and Interstate, Merrimack and South Coastal Small Municipal Separate Storm Sewer Systems (MS4) General Permit

Comment Letter to EPA Region 1 

Comment letter in response to the Environmental Protection Agency’s (EPA) questions on its proposed Sanitary Sewer Overflows (SSOs) and Peak Flow Rulemaking.

Comment Letter to EPA

Wastewater

Comment Letter to EPA about its development of public notification requirements for combined sewer overflows (CSO) into the Great Lakes, including concerns about requirements for how the public is notified, schedules, timeframes for notifications, monitoring and reporting.

Comment Letter to EPA

Comment letter, testimony, and position paper to the Joint Committee on Environment, Natural Resources and Agriculture (JENRA) supporting Bill H.4254 - An Act to enable the Commonwealth’s administration of the Massachusetts Pollution Discharge Elimination System.

Comment Letter to JENRA on Bill H.4254

Testimony to JENRA on May 17, 2016

Position Paper on Primacy

Comment letter to the Massachusetts Clean Water Trust critiquing the proposed affordability calculation to govern distribution of principal forgiveness for the State Revolving Fund.

Comment Letter to Massachusetts Clean Water Trust

Request to EPA supporting the Center for Regulatory Reasonableness’s (CRR) request for a Science Advisory Board (SAB) review of EPA Region 1’s Sentinel Approach for numeric nutrient criteria for estuarine waters, specifically in the Taunton River Estuary.

Letter Request to EPA

Comments on MassDEP’s proposed Regulatory Changes, commending the department for its efforts to streamline the regulatory process and eliminate duplicative programs, and offering suggestions for further improvements.

Comment Letter to MassDEP

Comments on the Clinton Wastewater Treatment Plant Draft NPDES Permit, with particular concern noted over the proposal to make the towns of Clinton and Lancaster co-permittees, and the imposition of a new, unfunded treatment mandate that will increase costs for residential and business rate-payers.

Comment letter to EPA and MassDEP

Comment letter on EPA Improving Regulations Docket.

Comment Letter to EPA

Comment letter in response to Massachusetts Department of Environmental Protection’s (MassDEP) proposed changes to Clean Water State Revolving Fund (SRF) Interest-Free Loan Program

Comment Letter to MassDEP Director of Municipal Services McCurdy 

Other

Comment Letter to EPA about Executive Order 13777, “Enforcing the Regulatory Reform Agenda” listing a number of MCWRS’s concerns, including the lack of EPA emphasis on integrated planning, lack of funding, shortcomings of the MS4 permit, and support for delegating NPDES authority to MassDEP.

Comment Letter to EPA

Comments in support of Senate Bill 1880 and the efforts of Senate President Therese Murray and Senator James Eldridge to raise awareness about the need for greater state assistance for municipalities and districts burdened by enormous costs to maintain and improve water infrastructure.

Letter to Joint Comittee on Environment, Natural Resources and Agriculture

Comments on the U.S. Environmental Protection Agency’s Draft 2014-18 Strategic Plan, welcoming EPA’s pledge to improve collaboration and cooperation with local partners, and also requesting that EPA recognize the unique challenges and issues regulated municipalities face that require them to balance their environmental initiatives with equally pressing and costly needs across their communities.

Comment Letter to EPA