October 1, 2019
The Plymouth Village Water and Sewer District has decided to join a small, but hopefully growing, coalition of impacted entities to challenge the recent process by which NHDES set standards for four PFAS chemicals. We did not take this step lightly, but the new rules will have a significant financial impact on the customers of our small water and sewer district. These new regulations will create a massive unfunded liability that the customers of the Plymouth Village Water and Sewer District, along with every other municipal utility in NH will be expected to absorb, without any consideration to the immediate or long term impacts on the users or sustainability of the systems.
We believe that the rushed rulemaking process leaves our customers and the community in a wholly untenable situation: forced to comply with a very aggressive set of rules without any indication of how and to whom the costs will be allocated. We cannot afford to adopt a “wait and see” attitude given the magnitude of the cost and the potential consequences to the District. We are in the environmental protection business right along with NHDES, we work with them every day, and we’re certainly not opposed to appropriate regulation based on sound science and consideration of the costs and benefits of the regulations. However, without the funding to support implementation this is an unfunded mandate that we cannot absorb or passively accept. We respect the folks at DES and understand their motivation but we believe that it did not have to be this way – with a little more time and a lot more discussion and collaboration with those in the field we could likely have achieved a more workable result. It is our hope that this challenge will result in a forced “do over” that can ultimately lead to the environmental protections that we all want at a price that we can all afford.