Public comment on Metropolitan Water Reclamation District of Greater Chicago’s Ethics Ordinance & Lobbying Requirements - Metropolitan Planning Council

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Public comment on Metropolitan Water Reclamation District of Greater Chicago’s Ethics Ordinance & Lobbying Requirements

Thank you to Commissioner Shore and the board for calling this study session on MWRD’s Ethics Ordinance and the lobbyist registration and reporting requirements that took effect earlier this year.   

2020 marks the 86th year of the Metropolitan Planning Council’s existence. During this time, we have provided support and partnership to state, regional, and local governments to implement policies that increase the vitality of our region, and outcomes that are equitable for all those that call Cook County home.   

As a 501(c)3 organization, we have been fortunate to sustain our work through philanthropic donations which allow us to conduct research, provide input, and assist with solving technical challenges, including for district staff and the board.   

Our good financial fortune has allowed our staff the time to comply, to the best of our abilities, with the current ordinance. We have been able to:  

  • Assess the impacts of this ordinance on our work; 
  • Seek legal determination and assistance on getting into compliance; and   
  • Work through the practical challenges of using a faulty reporting tool.  

All of this work takes both time and money; neither of which can we get back, or apply to higher and better uses in communities of need.     

I share this with you, because we’re fortunate.  

Here are some recent examples of contact with staff and commissioners that would appear to require reporting: 

  • Participation on the Watershed Management Ordinance’s Technical Advisory Committee, including any feedback requested by District staff to improve the ordinance or identify disproportionate impacts of a proposed change; 
  • Response to any request for information by Staff, including research and analysis in support of the Stormwater Volume Trading pilot; 
  • Advisory meetings or working groups where district staff or board are participants, including the cross-sector Calumet Stormwater Collaborative, an initiative facilitated by my colleagues, where public, private, non-profit organizations, and community groups come together to address stormwater problems in the Calumet region.  

In these cases, and others, we have navigated the bumpy rollout of the reporting requirements alongside all the other challenges of this unprecedented year.   

However, this Ethics ordinance—as it is written, interpreted, and currently in practice—has:  

  • Spread fear among many of our partner and peer community organizations; and  
  • Suppressed community participation from organizations who are not as fortunate as ours to have the time, money, and access to legal and other resources to comply with the ordinance.    

We ask that the board move quickly to:  

  • Implement a moratorium on application of this ordinance for 501(c)3 organizations until a time at which a just and equitable solution can be determined; and 
  • Establish a temporary Advisory Committee to assess the impacts—intended and unintended—of the Ethics Ordinance as it is written, interpreted, and currently in practice.   

Thank you for hearing our concerns, for moving quickly in the last few weeks to action.  

Before I conclude, I wanted to share with the Board a phrase that has taken on a dual resonance for me in light of this study session. Disproportionately Impacted Area. This phrase, which MWRD staff have recently refined the definition of during the course of §208.2 study. We have this powerful definition because this board requested action. We now have maps that show which communities in our region experience impacts from stormwater are not equitable.  

This ordinance, in the current state, has a disproportionate impact on organizations like ours, and many more, smaller community organizations.  

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