Lawyers for the Conservation Law Foundation argued before a federal environmental appeals board Thursday that the Environmental Protection Agency had not done its due diligence when creating a new permit for Manchester’s wastewater treatment facility.

Thursday’s oral arguments were the culmination of a months-long battle between environmental advocates, federal regulators, and city officials over what, if anything, should be done to protect the Merrimack River and people who live nearby from harmful chemicals coming out of the plant.

PFAS chemicals, also known as “forever chemicals,” are widely present in the environment and in the waste stream. Wastewater treatment processes don’t add PFAS to water, but they collect and transform those chemicals, putting them back out into the environment. A 2019 study found PFAS concentrations above federal drinking water standards being discharged from Manchester’s wastewater plant, and other studies found PFAS chemicals in fish from the Merrimack river.

The permit approved by the EPA requires the city of Manchester to monitor for PFAS chemicals in the wastewater entering their treatment plant, but it doesn’t put a limit on the levels of PFAS that can be in the water leaving the plant.

Lawyers with the Conservation Law Foundation argue the Environmental Protection Agency did not fulfill their duty to analyze whether the PFAS chemicals coming out of Manchester’s wastewater treatment plant could potentially harm the Merrimack River.

Jillian Aicher, a staff attorney with the Conservation Law Foundation, said that kind of analysis would be the first step to creating requirements to reduce the discharge of those chemicals.

“This appeal has very important implications for community members in Manchester, who are exposed to uncontrolled PFAS coming from their wastewater treatment plant with no reduction measures. And importantly here, no consideration by EPA of reduction measures,” she said.

Lawyers for the EPA argued the agency did consider the potential of effluent from the treatment facility to harm water quality. Federal regulators reviewed and agreed with an analysis done by New Hampshire state officials, they said.

In 2021, the EPA adopted a PFAS roadmap that includes restricting how much PFAS industrial facilities can discharge, and using the permitting process for wastewater facilities to reduce those chemicals in waterways.

Across the country, states have begun working to research and regulate PFAS in the waste stream. But the PFAS analysis that the Conservation Law Foundation is asking regulators to conduct for the Manchester plant is not common, said Tom Irwin, a vice president at the foundation.

He said Manchester would be an important place to start. The wastewater treatment facility, which is near some residential areas, burns its sewage sludge.

“People are being exposed to PFAS in the air, PFAS are being discharged into the water,” he said. “If the regulators take this on the way they should, this will provide a pathway for others.”

Environmental justice

The Conservation Law Foundation also argued the EPA abandoned environmental justice considerations during the permitting process without a thorough explanation.

Irwin told the Environmental Appeals Board that the agency’s reliance on executive orders that revoked Biden-era environmental justice policy was not enough, and that the policy change required more explanation.

“There is a growing body of case law that reaffirms that agencies can’t just change policy without analyzing why they’re doing so,” Irwin said in an interview with NHPR. “There’s no document from the Trump administration explaining why suddenly we don’t have to take into consideration communities that are overburdened by pollution and other health impacts.”

Lawyers for the EPA said the agency is allowed to use their discretion on environmental justice issues, and argued they did provide reasons for not considering environmental justice while they were drafting the permit.

Adam Dunville, a lawyer for the city of Manchester, also participated in the oral arguments in support of the EPA’s position. Officials with the city’s wastewater treatment plant staff did not respond to requests for comment.

Our readers – you folks – have really come through in sharing your ideas on what to do about taxes in New Hampshire. I am so grateful!

Now what to do. I will post this DAY 4 group of reader ideas here including a link that has the other three days worth of opinions. And will have a DAY 5 Friday because the tax ideas keep coming. Send to nancywestnews@gmail.com

This link contains links to DAYS 1, 2, 3

RON RAYNER, Concord, NH
The current system is badly broken and over-reliant on property taxes by years of neglect and the presence of Free Staters within our Legislature; the “balance” that could be achieved and should be sought for is now WAY out of control. Like the “fulcrum” on the see-saw, now badly broken.

Tax Remedies — Framework

1) Business Profits Tax — Slowly, incrementally increase the Business Profits Tax back to where it was before Sununu mucked up the works; it’s still lower than the surrounding states.

2) Dividends & Interest Tax —Reinstitute. Make adjustments such that it allows a higher base amount to be tax free; simply increase that base and return the same % tax on interest (as prior) up to, say, $50K; then increase the % tax on interest higher than $50K such that it effectively becomes a graduated tax on interest.

3) Broad-based Tax — is critical. I vote for a sales tax; Why? Because it spreads it out over a much wider base, including ALL of our tourists who utilize our infrastructure just as we residents do. The lowest sales tax in all states in New England is ME at 5.5%. If we imposed one at 5.0%, yes, that would cut into and hurt our gross sales $$. No doubt. BUT, limit it to something much lower, like 1.5% to 2.0% as a cap. Then the key becomes, just like other states have struggled with, what does it apply to? There should be wide exemptions for food and housing; clothes should have a $ limit like, say, up to $750 or even $1K is exempt; anything over is subject to the 1.5% tax. These exemptions, if done right, make it fair, even to the poorest amongst us. 

4) 3-3 Tax Plan by Andru V. — Yes, I do believe it would remedy MUCH of what is broken and would overall be fair. BUT, guess what? I maintain that an income tax, no matter how it’s structured, will FAIL. A low % sales tax will have a better (slightly) chance of passage because of A) the exemptions carved out, and B) it spreads it among MANY (i.e., out of staters).

5) Gas Tax — Leave it alone because we are already 42 years behind on maintaining our roads and the number of red-listed bridges.

6) Highway Toll Taxes — Increase all tolls for everyone to $1. Wow! A 30-cent increase for those of us with EZ-Pass; that’s a no-brainer! Is it “legal” to increase the highway toll on just out of staters? I support that, but also question that, although, admittedly, I’m not an attorney.

7) Not for Profits 501(c)(3) Organizations — They proliferate everywhere, especially in a “Capital City” like Concord. They need to contribute somehow, like some small % of their gross revenue. I can imagine the criticism, but we need to start somewhere.
RON RAYNER, Concord, NH

JENNIFER SIEGRIST
Below are my tax thoughts…
Because I read your articles and those of Garry Rayno’s, I feel I am well informed and, as such — mostly pissed off! 

Thank you for all the tireless efforts you and your entire newsroom put into InDepthNH. I truly value the coverage you provide and know you deserve every award you have all received and many more. 
JENNIFER SIEGRIST, Milford, NH

CHUCK RHOADES, Dover, NH
We recently received our property tax bill in the mail. While I don’t begrudge paying taxes for services, even those I may not use, I am alarmed at the ever-increasing property taxes and the inequality of our tax structure that it represents.

While not absolving municipal officials from their responsibility for prudent management, the fault for these increases seems clearly to lie with our elected state and federal officials. At the state level, the extremist Republican Free Staters control the state legislatures and apparently the governor too. They have eliminated the interest and dividend tax, which mostly wealthy people paid. They continue passing exorbitant subsidies for private schools, directly competing with our public school system. Our schools are fed by our property taxes to a degree greater than any other state in the country since we are dead last in state funding for education.

Less attention is paid to the effect that federal action (or inaction) has on our property taxes. Carleigh Beriont, candidate for the Congressional District 1 nomination, brings a fresh perspective to this problem. In her platform, viewable at CarleighBeriont.com, she notes that a key factor in our increasing property taxes is the federal government’s failure to fully fund the Individuals with Disabilities Education Act. Special education costs drive increases in local school budgets and this law promised to provide 40% of these mandated expenses. The actual allocations have never come close to fulfilling that promise.

Carleigh Beriont’s analysis of this federal obligation and her willingness to pursue this issue if elected demonstrates her thoughtful grasp of the problem. She has similarly thoughtful perspectives on other issues as well. I encourage property owners and all other voters to give her website a look.
CHUCK RHOADES, Dover, NH

BURT COHEN
I’ve long wondered if we’ll finally come to our senses and pass an income tax in my lifetime. Chances are dwindling the older I get.
BURT COHEN

CORNELIA SCHNEIDER
New Hampshire’s Fiscal Mirage

While some New Hampshire legislators wear buttons proclaiming “Taxation is Theft,” most of us believe that smart and fair taxation is the necessary price for a civilized society. Unfortunately, our current tax system is neither smart nor fair. The so-called “New Hampshire Advantage” has become a windfall for the wealthy and large corporations, leaving middle-income families, lower-income households, and small businesses behind.

To restore balance, we should reinstate the Interest and Dividends (I&D) tax, provided we include protections for seniors who rely on that income for retirement. Simultaneously, we must address the school voucher program, which is currently draining the general fund and should be repealed.

The state’s fiscal health is more precarious than leadership admits. For the first time since the Great Recession of 2008, the government has been forced to tap into the “Rainy Day Fund” to balance the budget. Without a natural disaster or pandemic to blame, the state withdrew over $67 million — roughly 25% of the fund — to cover revenue shortfalls and fund school vouchers.

The only thing preventing a deeper dip into our “Rainy Day Fund” was a one-time infusion from a tax amnesty program. We are facing significant financial trouble, yet the Governor and Concord continue to “fiddle while Rome burns.”
CORNELIA SCHNEIDER, Moultonborough, NH

ADAM FINKEL
I appreciate everyone who has mentioned the folly of eliminating the 5% Interest/Dividends tax. I would willingly continue paying it if it was reinstated. And, simply by exempting all payments under $1,000 (not dividend income of $1,000 — payments of $1,000, or 5% of at least $20,000 in dividends), the state could raise about $150 million annually (a bit less than the $160 million that was formerly collected including the small payments). Someone paying between $1,000 and $10,000 per year in passive income would have assets in the $1-2 million range or higher; surely, they can easily afford 5% of this passive income, leaving the other 95% to accumulate.

But as regressive as our overall tax system is in NH, there is one aspect that is even more slanted toward the rich: the “Current Use” rates. I support lower taxes on large open space lots, so that owners won’t have an incentive to subdivide and sell. But I had no idea (until I looked!) at just how big a subsidy a 10-acre (or more) plot gets over a smaller one. I gladly pay about $3,600/acre in tax for a small parcel next to my cabin — but if it was 10 acres or more, the tax would be about $6/acre! Not $600, not $60, but $6.

SURELY there is a price point between $6 and $3,600 — let’s call it $60/acre — where an owner would still have no reason to sell, but where the state could reap some revenue for education, infrastructure, environmental protection, etc.
ADAM FINKEL, Dalton, NH

RICH DiPENTIMA
The NH tax system is one of the most unfair in the nation. Almost every tax that individuals pay, either directly or indirectly, are very regressive and have little relationship to one’s income. For example, property taxes, rooms and meals tax, gasoline tax, and tobacco taxes have no relationship to income. Those who pay rent pay the property owner’s property taxes through their rent, which has no relationship to income. The only tax that NH has that was related somewhat to income was the interest and dividends tax, which has now been repealed.

As a result, low and middle-income people pay a much larger percentage of their income on taxes than the wealthy (see below). This is what the Republicans call the “NH advantage.” Yes, a huge advantage for the rich. And as a result, we do not get the services provided by other states, or they must be provided by the cities and towns through property taxes.

Tax Burden by Income Level (2026 Context)

• Lowest 20%: Pay the highest effective state and local tax rate, often over 3 times higher than top earners, due to high property taxes (including those in rent) and consumer taxes.
• Middle 20% ($62,300–$104,100): Face an effective tax rate roughly 2.4 times higher than the top 1%.
• Top 1% (>$721,000): Pay the lowest effective state and local tax rate, estimated at around 2.8% of their income. [1] RICH DiPENTIMA

JUDY ULLMAN
I think an income tax is the only thing that makes sense.
JUDY ULLMAN

THOMAS MAINVILLE
Here is one way to bring a lot of extra money into the state: legalize recreational cannabis and tax it. There’s so much money going to MA, VT, and ME, and it’s all taxed. There’s a lot of money to be made off it that’s just being spent in other states. If it was made recreational and was taxed, many people wouldn’t mind paying a tax since they already are.
THOMAS MAINVILLE

OWEN MCISAAC
Thank you for this opportunity to share perspectives on taxes in New Hampshire.

Our family goes back four generations in the state. We came from Canada to build roads, staff mills, and be part of the economy. None of us has been rich, but our work supported the wealthy. We thought that if we worked hard and saved money, we would be alright.

Year after year, the tax rate rises disproportionately to what used to be a middle-class income. Now, the unthinkable has happened — we will have to leave the state and find another way to survive.

We watch at town meeting and in fora all over the state, the downshifting of state expense falling on municipalities and schools. We watch as terrified people attack them. I imagine those in the State House watching it all with glee. The sleight of hand worked!

I wish that there was more empathy among lawmakers. I wish that they understood that people like us who live in one-bathroom houses with no luxuries (none of us have ever had a dishwasher) do not buy alcohol, go out to movies, dine out, or do anything other than try to survive.

Thank you for this opportunity.
OWEN MCISAAC, Webster, NH

InDepthNH.org scans the websites of New Hampshire funeral homes each week and selects at random some of our friends, relatives and neighbors to feature in this column. The people listed here passed away during the previous weeks and have some public or charitable connection to their community. InDepthNH.org is now offering obituaries through the Legacy.com service. We view this as part of our public service mission. Click here or on the Obituaries tab at the top of our home page to learn more. And if you know of someone from New Hampshire who should be featured in this column, please send your suggestions to NancyWestNews@gmail.com.

Mary M. Blaisdell, 84, of Concord, died May 10, 2026. She was a lifetime achievement honoree of the East Concord Lamplighters, a member of the Concord School Board, and organized Concord High School Class of 1960 reunions as class treasurer. (Bennett Funeral Home)

Dorothy (Meade) Campbell, 84, of Grafton, died May 7, 2026. She had been a teacher and principal at Indian River and had served as selectman and treasurer for the Town of Grafton. (Chadwick Funeral & Cremation Service)

Socrates James Chaloge, 90, of Manchester, died May 7, 2026. He owned Leslie Studio, which he once operated with his father, Perry Chaloge. photographing more than 5,000 weddings throughout Manchester, in addition to countless portraits, schools, and pageants. His original oil photography portraits may still be viewed at the Hampton Historical Society, where he was recognized for photographing Miss Hampton Beach during the late 1950s and 1960s. He served in the Air National Guard.  He taught photography classes at the YMCA in Brockton, Mass., and founded and was president of the New England Trade Institute (NETI). (Legacy.com)

Norman A. Colburn, 80, of Laconia, died May 8, 2026. He served on the Laconia Fire Department for 21 years, advancing from driver to deputy fire chief. In retirement, he worked in loss prevention for the N.H. Municipal Association. (Wilkinson-Beane-Simoneau-Paquette Funeral Home)

Charles Henry Cummings Jr., 77, of Greenland, died May 10, 2026. He was a U.S. Army veteran. He worked at Pease Air Force Base in civil engineering positions and later as head of the Reports and Analysis Branch in the 509th Transportation Squadron. In 1991 he transferred to the Industrial Relations Office at the Portsmouth Naval Shipyard. He worked as a labor relations specialist for 12 years and was chief spokesman for management while negotiating the collective bargaining agreement between the shipyard and the American Federation of Government Employees. He served 12 years on the Greenland Budget Committee, three years on the Conservation Committee, two years on the Land Use Advisory Committee and four years as a selectmen, from 2008 to 2011. (Remick & Gendron Funeral Home)

David Holmes, 88, of Durham, died May 7, 2026. A U.S. Army veteran, he volunteered with the Peace Corps in 1963 andhelped establish savings and loan banks in Peru. He later become a Peace Corps administrator in the South Pacific islands of Tonga and Samoa. He was a career counselor at Fordham University, St. Lawrence University and UNH. (Kent & Pelczar Funeral Home)

John Linke “Jack” Lewis, 81, of Peterborough, died May 8, 2026. He spent his career with Chemical Bank in New York City, later JP Morgan Chase Bank, retiring in 2001 as senior vice president. He and his family moved to Dublin in 2002, and in 2020 to Peterborough. He was treasurer of the Peterborough Players and the Dublin Riding and Walking Club, and chaired the Dublin Conservation Commission. (Jellison Funeral Home & Cremation Services)

David Linatsas, 74, of Nashua, died May 10, 2026. He started his teaching career in special education in Nashua elementary schools. He then obtaining his doctorate in chiropractic at Life Chiropractic College in Marietta, Ga., andopened Nashua Family Chiropractic (known today as Lyphos Family Health). He retired in 2016 when his son, Brandon, took over the business. (Davis Funeral Home)

Robert Marquis, 72, of Stratham, died May 7, 2026. He was a counselor at Amesbury (Mass.) Middle School and then worked at SAU 21 in Hampton as a school psychologist. He was director of pupil services in Deerfield, special education director in SAU 56 in Somersworth, and assistant superintendent in Somersworth. He became superintendent of schools in Milford. (Remick & Gendron Funeral Home-Crematory)

Eric Paul Rochette, 55, of Nashua, died May 12, 2026. He was the owner of Rochette Funeral Home & Cremation Services in Nashua. He followed his father Paul into the funeral profession and had been a licensed funeral director and embalmer since 1991. He purchased the funeral home from his father in 2014, and he and his wife Deanna, became co-owners in 2019. He was a New Hampshire state representative for District 31, Ward 4 from 2005 to 2006 and for District 28, Ward 1 from 2007 to 2008. He served on the New Hampshire State Board of Funeral Directors and Embalmers from 2015 to 2020. He was a member of the Actorsingers of Nashua. (Rochette Funeral Home & Cremation Services)

Jack Tatirosian,M.D., 94, of Atkinson, died May 9, 2026. He was a captain in the U.S. Air Force and began his medical practice in 1966 in Haverhill, Mass. He was an internist and founding member of Pentucket Medical Associates. He retired in 2000. He was a staff member of Hale Hospital where he was also the chief of medicine for two years. (H.L. Farmer & Sons Funeral Home)

Scott Evan Trexler, 61, of Moultonborough, died May 8, 2026. He worked at Trexler’s Marina on Lake Winnipesaukee since he was a child. The marina was bought by his parents in 1972, and when his father died in 1980, he became more involved in the business, eventually assuming the role of general manager. (Mayhew Funeral Home) 

Ronald P. Voveris, 81, of Nashua, died May 13, 2026. He was a U.S. Army veteran and a social studies teacher at Nashua High School and then Elm Street Junior High School, where he dedicated 34 years. He Ron coached the “Twins” Babe Ruth baseball team for a decade and freshman baseball for Nashua High School. (Farwell Funeral Service)

WORDS OF WISDOM: “Life is never easy. There is work to be done and obligations to be met – obligations to truth, to justice, and to liberty.” — John F. Kennedy, 35th U.S. President, May 29, 1917, to Nov. 22, 1963