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Earth Night

Chairman Wilkerson and members of the Committee:

My name is Pamela DiBona, I am Vice President for Policy at the Environmental League of Massachusetts. Thank you for the opportunity to testify regarding the important proposals put forward by Governor Romney. The proposal for a new Office of Commonwealth Development contains many good ideas, yet it raises many questions and concerns on our part as well.

First, we commend the Governor for taking the initiative to coordinate the housing, transportation, energy, and environmental aspects of state policy. We have long advocated for better integration of these functions, as we watched transportation and housing projects send sprawling development in all directions. The amount of land developed in Massachusetts over the past 50 years far outstrips the rate of population growth. Between 1990 and 2000, the state's population grew by 11 percent while the amount of developed land increased by roughly 44 percent. This type of sprawling development leads to a number of significant environmental problems. Massachusetts ranks 10th in time wasted in traffic, contributing to our air pollution problems. Our urban areas are filled with brownfields that are sitting vacant. Many community are experiencing serious water supply shortages, and our rivers are drying up, making them less able to handle wastewater and unable to support diverse aquatic wildlife. We are losing valuable farmland and open space.

The solution is not to prevent development altogether, but to chose wisely where that development should go. A choice between environmental protection and affordable housing, or clean air and water and economic development, is not a choice that residents of the commonwealth should have to make.

In recent decades, Massachusetts' approach to shaping development and land use has devolved into a collection of isolated programs, incentives, and disincentives that often work at cross-purposes. There has been almost no policy coordination, either horizontally or vertically. While sprawl has expanded, traffic congestion has worsened, economic divisions have widened, and housing costs have grown faster than anywhere else in the country, state leaders have not given coordinated growth management and anti-sprawl efforts a high profile. This is in marked contrast to the state commissions, governor's cabinets, state planning offices, and new legislation championed by governors and other leaders in many other states, including our New England neighbors in Vermont, Maine, Rhode Island, and New Hampshire. We see the new Office of Commonwealth Development - which we propose should be called the Office of Commonwealth Resources - as a step in the right direction for better coordination and ultimately, better outcomes for our environment, public health, and overall quality of life.

Of course, a challenge for the current and future Chiefs of Commonwealth Resources will be to truly balance the sometimes competing demands of the three arenas. This is why the Secretary of Environmental Affairs (now Secretary of Environment) must remain a cabinet-level position, and must have the resources and autonomy needed to carry out the mission of the Secretariat and its agencies, as well as advocate on behalf of environmental protections in the Office of Commonwealth Resources.

We also have several concerns and suggestions regarding the specific proposals outlined in the Governor's draft reorganization:

1. The budgets for the Office of Environment and its Divisions reflect the Governor's proposal to move agency attorneys to an Office of Solicitor General. We strongly oppose that move, and will provide separate testimony next week regarding that proposal.

2. The Department of Environment should continue to house the Administrative Council on Toxics Use Reduction, as provided in the Toxic Use Reduction Act.

3. The concept of an Office of Sustainable Development is a good one. We urge you to consider establishing another office with a similar structure (a director in Office of Commonwealth Resources, and Teams in each Division) to focus on environmental justice issues. This is a similar overarching concern here in Massachusetts, which should be brought into consideration early in any development proposal.

4. We do not agree that all land acquisition tasks should be consolidated into the Department of Environment under the Office of Land Acquisition and Protection. While a state coordinator would be a reasonable mechanism for making sure that acquisition efforts are complimentary, the different acquisition programs are important to maintain so that a diversity of land types, values, and locations are preserved.

5. While we appreciate the formation of a new Stewardship Council in the Division of Conservation and Recreation, the legislation must include more detail about the powers, duties, and responsibilities of that body. The Environmental League has been working with two parks advocacy coalitions (one focusing on metropolitan parks, the other on state forests and parks) to draft an alternative proposal for the Council.

6. The Division of Conservation and Recreation should maintain control of the state forests, reflecting the primary values we hold for Massachusetts' natural resources: first and foremost, our forests must serve as habitat for wildlife and recreation areas for our citizens, not as money-making enterprises.

7. We need to see more detail regarding the proposed management and maintenance of the MDC and DEM parkways. The current proposal refers to an MOU that will be developed between the Secretaries of Environment and Transportation, with implementation by a Bureau of Parkways in the Transportation secretariat. Until we see what that MOU entails, and proposed mechanisms for revising the standards set out, we question the long-term wisdom of moving responsibility from the environmental agencies.

8. We propose that the Bureau of Environmental Law Enforcement be transferred to the Department of Environment, as its own Office. The park police, MDC police, and environmental police officers have stated their preference to be housed in one office, with the ability to share resources more fully, and shift resources as needed. Given the difficulty each jurisdiction has experienced in maintaining full staffing and obtaining the resources needed to carry out their important missions, we fully support their proposal.

Finally, we disagree that the cuts sustained by the environmental agencies are the result of reorganization and efficiency gains. Over the past years, faced by consistent decreases in funding, the agencies have implemented many, many efficiencies to keep existing programs intact, even while new responsibilities have been added. House 1 represents direct cuts to programs. The Department of Environmental Protection, for example, lost 15 percent of its staff last fiscal year, and is predicting further layoffs that will result in a 22 percent layoff over 2 fiscal years. This means cuts in technical assistance to municipalities and local commissions, no recycling grants for cities and towns, and a loss in momentum among the multitude of nonprofit organizations that were helping the government clean up Massachusetts' land and water. Certainly these programs do not fall in the category of "waste and abuse," nor is cutting these programs a logical outcome of reorganization.

Thank you for the opportunity to testify, and we look forward to working with you and the Administration to see these changes com