SPRINGFIELD WATER AND SEWER COMMISSION & Others v. DEPARTMENT OF ENVIRONMENTAL PROTECTION & Another

CourtMassachusetts Appeals Court
DecidedJuly 31, 2025
Docket24-P-931
StatusPublished

This text of SPRINGFIELD WATER AND SEWER COMMISSION & Others v. DEPARTMENT OF ENVIRONMENTAL PROTECTION & Another (SPRINGFIELD WATER AND SEWER COMMISSION & Others v. DEPARTMENT OF ENVIRONMENTAL PROTECTION & Another) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
SPRINGFIELD WATER AND SEWER COMMISSION & Others v. DEPARTMENT OF ENVIRONMENTAL PROTECTION & Another, (Mass. Ct. App. 2025).

Opinion

APPEALS COURT

SPRINGFIELD WATER AND SEWER COMMISSION & others[1] vs. DEPARTMENT OF ENVIRONMENTAL PROTECTION & another[2]

Docket: 24-P-931
Dates: April 14, 2025 – July 31, 2025
Present: Blake, C.J., Shin, & Walsh, JJ.
County: Suffolk
Keywords: Municipal Corporations, Water supply, Water commissioners. Water. Regulation. Department of Environmental Protection. Administrative Law, Agency's interpretation of regulation, Rulemaking. Practice, Civil, Judgment on the pleadings.

      Civil action commenced in the Superior Court Department on February 17, 2023.

      The case was heard by Catherine H. Ham, J., on motions for judgment on the pleadings.

      Peter F. Durning for the plaintiffs.

      Louis M. Dundin, Assistant Attorney General, for the defendant.

      Harley C. Racer for the intervener.

      Kevin Cassidy, for Massachusetts Rivers Alliance, Inc., & others, amici curiae, submitted a brief.

      SHIN, J.  In 2023, after an extensive rulemaking proceeding, the Department of Environmental Protection (department) promulgated amendments to its regulations implementing the Massachusetts Water Management Act, G. L. c. 21G (act).  The Legislature passed the act in 1985 for the purpose of promoting better water management and water conservation in the Commonwealth.  See Concord v. Water Dep't of Littleton, 487 Mass. 56, 58 (2021); Water Dep't of Fairhaven v. Department of Envtl. Protection, 455 Mass. 740, 745-747 (2010) (Fairhaven).  To that end, the act imposes a "withdrawal volume threshold" of 100,000 gallons per day, prohibiting water suppliers from making a withdrawal from a water source in excess of that amount without either (a) obtaining a permit from the department or (b) filing a registration statement with the department.  G. L. c. 21G, § 4.  The latter path, withdrawal by registration, is available only to suppliers that had existing rights to withdraw more than the threshold volume as of the act's effective date.  The act allowed any such supplier to preserve its existing rights by filing a registration statement by January 1, 1988; the registration statement, if timely renewed, then allows the supplier to "continue forever to withdraw water at the rate of its existing withdrawal."  Fairhaven, supra at 742.  See G. L. c. 21G, § 5.

      At issue in this case is a provision in the amended regulations that requires registrants to "establish enforceable restrictions limiting nonessential outdoor water use" during periods of drought.  310 Code Mass. Regs. § 36.07(2)(c) (2023) (§ 36.07[2][c]).[3]  Claiming that this requirement infringes on their rights to existing withdrawals and is arbitrary and capricious, the plaintiffs -- a group of water suppliers holding registrations under the act and a trade association -- filed a complaint for judicial review under G. L. c. 30A, § 7.  On the parties' cross motions, a Superior Court judge granted judgment on the pleadings for the department and the defendant intervener, Charles River Watershed Association.  In a comprehensive memorandum of decision, the judge concluded that § 36.07(2)(c) restricts water use, not water withdrawals, and thus does not infringe on the plaintiffs' existing rights, and that the plaintiffs failed to meet their burden of showing that § 36.07(2)(c) is otherwise arbitrary and capricious.  We agree and thus affirm.[4]

      Background.  1.  Statutory framework.  The act was prompted by "calls for action issued by two separate studies, one commissioned by the executive branch and the other by the Legislature," which stressed the need for a "comprehensive approach to water conservation in the Commonwealth."  Fairhaven, 455 Mass. at 745.  The act requires the department and the water resources commission (commission) of the Executive Office of Energy and Environmental Affairs (EEA) to "cooperate in the planning, establishment and management of programs to assess the uses of water in the commonwealth and to plan for future needs."  G. L. c. 21G, § 3.  The commission's mandate is to "adopt principles, policies and guidelines necessary for the effective planning and management of water use and conservation in the commonwealth and for the administration of [the act] as necessary and proper to ensure an adequate volume and quality of water for all citizens of the commonwealth, both present and future."  Id.  The department's mandate is to promulgate "regulations as it deems necessary to carry out the purposes of [the act], establishing a mechanism for managing ground and surface water in the commonwealth as a single hydrological system and ensuring, where necessary, a balance among competing water withdrawals and uses."  Id.  As is evident from the statutory text and legislative history, "water management, including water conservation, is an important purpose of the [a]ct, and the department . . . has broad authority to issue regulations to carry out this purpose."  Fairhaven, supra at 746-747.

      As mentioned, any supplier that had existing withdrawal rights in excess of the 100,000-gallon volume threshold and that had filed a registration statement by January 1, 1988, is entitled to continue to withdraw water at the rate of its existing withdrawals so long as it timely renews its registration statement.  This entitlement is established by G. L. c. 21G, § 5, which states that "[a]ll initial registration statements filed [by January 1, 1988,] for existing withdrawals from the water source shall authorize such withdrawals until the next applicable expiration date . . . " and "[u]pon the expiration of any initial or renewal registration statement under this section, the registrant shall be entitled, upon the filing of a renewal registration statement, to continue existing withdrawals specified in the registration statement for a period of ten years."  The department may not restrict a registrant's existing withdrawals with one exception.  That is, on the petition of an "operator of a public water system," the department may declare "a state of water emergency," G. L. c. 21G, § 15, which then empowers it to "[d]irect any person to reduce, by a specified volume, the withdrawal or use of any water; or to cease the withdrawal or use of any water."  G. L. c. 21G, § 17 (3).  See Fairhaven, 455 Mass. at 742 n.4.

      In contrast to registrants, suppliers without existing withdrawal rights must obtain a permit from the department to withdraw water in excess of the 100,000-gallon volume threshold.  See G. L. c. 21G, § 7.  The department has broad discretion to issue or deny permits based on factors such as "the impact of the proposed withdrawal on other hydrologically interconnected water sources, the water available within the proposed water source's safe yield, and '[r]easonable conservation practices and measures, consistent with efficient utilization of the water.'"  Fairhaven, 455 Mass. at 748, quoting G. L. c. 21G, § 7.  The department may also "attach to any permit whatever conditions it deems necessary to further the purposes of [the act] or to assure compliance with its regulations."  G. L. c. 21G, § 11.

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SPRINGFIELD WATER AND SEWER COMMISSION & Others v. DEPARTMENT OF ENVIRONMENTAL PROTECTION & Another, Counsel Stack Legal Research, https://law.counselstack.com/opinion/springfield-water-and-sewer-commission-others-v-department-of-massappct-2025.