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LOCAL GOVERNMENT 
MANDATES IN PENNSYLVANIA: 

HOW “BURDENSOME” ARE THEY?

Paula a. DuDa Holoviak

Kutztown University

Although the issue of state mandates has been off the agenda in recent 
years, the fiscal constraints imposed by the “new normal” for state and 
local governments has brought the issue to the foreground once again at the 
state level. This article examines the impact of state mandates as perceived 
by local governments in Pennsylvania. Pennsylvania, as a Commonwealth, 
has a unique relationship with its many forms of local government, which 
results in policymaking by bargaining as well as by statute. This article is 
the result of a comprehensive 2010 survey of the types of state mandates 
and their impact and cost to local governments in Pennsylvania. This article 
focuses upon the different responses to state mandates generated by the 
varied types of local government in Pennsylvania. In particular, it focuses 
upon resource and administrative constraints for rural as opposed to urban 
municipalities.

While federal and state mandates have received a great deal of 
academic and legislative scrutiny in the past 40 years, they have recently 
taken a backseat to more pressing issues at the local level. But mandates 
have not disappeared and, in fact, continue to play a large role in policy 
decisions, resource allocation, and administrative practices at the local level. 
Recently, the state senate in Pennsylvania commissioned a comprehensive 
study of the effects of state mandates upon local governments. Although 
the study was prompted by complaints from local government associations, 
the question remains as to how important is this issue? Given the fiscal 
constraints of recent years, how burdensome do local governments perceive 
these mandates to be? Moreover, is this burden different for larger versus 
smaller or urban versus rural local governments? This research seeks to 
address these two questions by examining survey data gathered in 2011 by 
the Pennsylvania Local Government Commission. Descriptive statistics and 



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LOCAL GOVERNMENT MANDATES IN PENNSYLVANIA

tests of differences among groups are used to determine how burdensome 
state mandates are in the opinion of local governments.

Background on Mandates

The issue of mandates imposed by the federal government upon state 
and local government and by state governments upon local governments 
was very prevalent in research and legislation in the early 1980s and 
throughout the 1990s. Mandates can be broadly defined to include direct 
orders from one level of government to another, a crosscutting requirement 
or condition of aid, or any partial preemption of government functions by 
another level of government (Gormley 2006). The issue of state mandates 
placed upon local governments came to the forefront with the U.S. Advisory 
Commission on Intergovernmental Relations report, which found that 
state priorities were replacing local priorities due to the expanded use of 
mandates (ACIR 1990). Other studies have shown that while state mandates 
can provide equity in both the type of service provision and the quality of 
those services, state mandates, and in particular unfunded or under-funded 
mandates, can displace local priorities (Lovell and Tobin 1981; St. George 
1995). In addition, because the vast majority of state mandates involve 
administrative mandates rather than policy mandates, their effects and costs 
are much more difficult to track (Kelly 1997). Past strategies for dealing 
with the administrative and budgetary burdens caused by state mandates 
have included constitutional and legislatively mandated reimbursement 
requirements, fiscal notes or costs estimation for proposed mandates, voter 
approval, exceptions or exemptions from mandate provisions granted by 
the governor or legislature, and sunset legislation for existing mandates. 
However, the vast majority of these “fixes” have proven to be highly 
ineffective in dealing with fiscal and administrative costs (Lovell and Tobin; 
Zimmerman 1995; Grossback 2002).

The Pennsylvania Mandate Issue

The problems and costs associated with state mandates placed on local 
government appeared to have fallen off the issue agenda in recent years. 
However, the fiscal constraints imposed by the Great Recession and the 
associated decline in state and local revenue sources have brought the issue 
to the forefront once again. The “new normal,” as many researchers have 
dubbed the current crisis, involves shrinking local tax bases, permanent cuts 
in expenditures, layoffs, pension and benefit cuts, decreased capital spending, 
and cuts in local services (Martin et al. 2012). According to a 2012 report 
by the U.S. Census Bureau on the status of state and local governments, 
between 2007 and 2012, state and local government revenues declined by 



3

PAULA A. DUDA HOLOVIAK

1.1% with cash and security holdings declining 1.7%. During this same time 
period, indebtedness increased 22.2% from $2.4 trillion to $2.9 trillion. Local 
governments accounted for 61% of this debt (Barnett et al. 2014). It was in 
this atmosphere of retrenchment and fiscal austerity that Pennsylvania Senate 
Resolution 323 was commissioned on July 2, 2012. The Pennsylvania Local 
Government Commission, a state legislative agency, was directed to study the 
costs and the real and perceived effects of state statutory mandates upon all 
levels of Pennsylvania local government, counties, cities, boroughs, towns, 
and townships (PA Local Government Commission 2012).

According to the Local Government Commission, Pennsylvania 
has over 6,500 local government mandates, which include “direct order, 
a condition of aid, an authorization, a condition of an authorization, or a 
combination…” (Local Government Commission 2012: S-2).  Given 
this overwhelming number of mandates, the Commission chose a more 
restrictive definition of mandate for the commissioned study.

“Mandate” – A duty imposed by a law enacted by the General 
Assembly that is a direct order or condition of aid which requires 
that a municipality establish, expand or modify its activities 
or services in such a way as to necessitate expenditures from 
municipal revenues. A mandate shall not include any duty imposed 
by, required to implement, or necessary to avoid violating:… 
(Local Government Commission SRS 323 Study 2012: 2-31)

Excluded from this definition of mandate were any requirements 
imposed by a courts order, federal law, the U.S. Constitution, or the 
Pennsylvania Constitution as well as certain laws dealing with elections, 
municipal powers and structure, duties, powers and ethical considerations 
of public officials, collective bargaining agreements, and voter referendum 
(Local Government Commission).

Since local government administers roughly 84% of these state 
mandates, the Commission, with the assistance of a group of academic 
advisors, put together a multifaceted evaluation design to obtain measures of 
cost and perceived burden on local government. The methodology included 
a survey of state agencies (36) and all Pennsylvania local governments. 
This paper provides analysis of all the municipal survey results (excluding 
the counties) while providing more in-depth analysis of the results of the 
survey of Pennsylvania’s larger municipalities as classified by population 
and population density, cities, boroughs, and first-class townships. 

Methodology—Local Government Surveys

The Commission requested the major local government associations in 
the state to have their membership identify the most burdensome mandates. 



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LOCAL GOVERNMENT MANDATES IN PENNSYLVANIA

This was done by the use of mail and email surveys, through association 
newsletters, and by in-person surveys conducted at association annual 
meetings and conventions. The County Commissioners Association of 
Pennsylvania (CCAP) identified 17 mandates of which 13 were chosen as 
not being currently addressed or studied. Several municipal associations 
were surveyed: the Pennsylvania League of Cities and Municipalities 
(PLCM) (now the Pennsylvania Municipal League); the Pennsylvania State 
Association of Boroughs (PSAB); the Pennsylvania State Association of 
Township Commissioners (PSATC), which largely comprises  more urban 
first-class townships; and the Pennsylvania State Association of Township 
Supervisors (PSATS), which is a more rural based organization of second-
class townships. These associations identified 23 issues. Twelve of these 
issues were identified as either federal in nature and not state mandates, 
already studied, of little financial impact, or not measurable at this time, 
leaving 11 issues for the final survey. To develop survey questions based 
on the most burdensome issues identified by the associations, University 
led teams of students and professors then conducted field interviews with 
rural, urban, and suburban counties; cities; boroughs; first- and second-class 
townships in four regions across the state (three in Eastern Pennsylvania and 
one mix rural/urban in Western Pennsylvania). 

The Commission then formulated and conducted a survey of all 
Pennsylvania counties, cities, boroughs, and first- and second-class 
townships. An online survey instrument was used as well as a mail survey 
for those municipalities without email. The survey gathered information on 
costs estimates of mandates as well as the ranking of the perceived burden 
of these mandates. Of the 67 counties surveyed, 59 or 88% responded 
(results not discussed here). The 2,562 municipalities surveyed generated 
a 30% overall completion rate. A total of 1,108 cities, boroughs and first-
class townships responded (25%) to the entire survey but only 498 (45%) 
completed the ranking portion of the survey. Among the second-class, rural 
townships, 1,452 (34%) responded to the entire survey with 708 (49%) 
responding to the ranking questions.

Survey questions included rating mandates from not burdensome to 
very burdensome and estimates of costs associated with the implementation 
of these mandates. Costs were defined as direct costs of implementing 
mandates such as mandatory police collective bargaining arbitration and 
added costs to projects from mandated competitive bidding and advertising.  
In addition, the survey asked respondents to choose from a list of mandate 
“fixes” and to identify any other burdensome mandates not identified in 
the survey. The list of costs and mandate burden relief was generated by 
each of the municipal associations identified previously. Lastly the survey 
gathered general data on the location of the municipality and whether or not 
the municipality operated under a home rule charter. 



5

PAULA A. DUDA HOLOVIAK

Survey Findings

Appendices A and B provide a full list of the mandate-rating questions 
and responses for the municipal governments. Participants were asked to rate 
11 issues on a scale from not burdensome to very burdensome. These issues 
represented the mandates identified by the municipal associations. Thus the 
municipal respondents, who ranged from professional administrators to full- 
or part-time elected officials to clerks, could be assumed to have familiarity 
with the issues posed. Table 1 summarizes the rankings of these issues from 
most to least burdensome excluding the not applicable responses.

Table 1 
Most Burdensome Mandates (Most to Least) 

Source (Local Govt. Commission Mandate Survey 2011–2012)

Rank Cities, Boroughs, First-Class 
Townships

Second-Class Townships

Rank 1 Police and Firefighter Collective 
Bargaining Mandatory 
Arbitration

Prevailing Wage for Public 
Works Projects

Rank 2 Prevailing Wage for Public 
Works Projects

Police Collective Bargaining 
Mandatory Arbitration

Rank 3 Competitive Bidding & 
Advertising Requirements

Competitive Bidding & 
Advertising Requirements

Rank 4 Property Exempt From Real 
Estate Tax

Stormwater Facilities and Traffic 
Control Maintenance on 
State Roads

Rank 5 Right-to-Know Law 
Compliance

Advertising or Publication of 
Legal Notices

Rank 6 Uniform Construction Code 
Triennial Education & 
Certification

Separate Specifications and 
Bids for Public Buildings

Rank 7 Stormwater Facilities and Traffic 
Control Maintenance on 
State Roads

Right-to-Know Law 
Compliance

Rank 8 Police Certification and Training Property Exempt From Real 
Estate Tax

Rank 9 Advertising or Publication of 
Legal Notices

Uniform Construction Code 
Triennial Education & 
Certification

Rank 10 Separate Specifications and 
Bids for Public Buildings

Act 101 of 1988
Recycling Requirements

Rank 11 Act 101 of 1988
Recycling Requirements

Police Certification and Training



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LOCAL GOVERNMENT MANDATES IN PENNSYLVANIA

But just how burdensome do the municipalities find these issues to be, 
given that the state associations strongly urged action on 23 different 
mandates? Table 2 summarizes the survey results for the top two ranked 
most burdensome mandates for cities, boroughs, and first-class townships.

Table 2 
Police and Firefighter Collective Bargaining Mandatory Arbitration and 

Prevailing Wage for Public Works Projects (Cities, Boroughs, and First-class 
Townships)

Mandatory 
Arbitration

Prevailing 
Wage

Frequency Percent Frequency Percent

Not Burdensome 38 10.1 73 16.9

Moderately Burdensome 73 19.4 161 37.4

Very Burdensome 265 70.5 197 45.7

Total 376 100 431 100

It is interesting to note that the not applicable response number for 
the collective bargaining question was 86 (18.6%) and for prevailing wage 
only 31 (6.7%). Based on the field interviews, it was found that many 
municipalities do not deal with all of these mandates on a monthly or 
even yearly basis (Author 2011). In fact, in examining the bottom ranked 
issues, separate specifications and bidding for public building projects and 
mandatory recycling, only 8.9% and 2.7% of larger municipalities found 
these mandates to be burdensome.

Likewise for the top two most burdensome mandates for more rural 
second-class townships, while 72.9% of respondents rank prevailing wage 
as very burdensome and 62.1% find police collective bargaining mandatory 
arbitration very burdensome only a little over 10% find recycling or police 
certification to be an issue. Note that second-class townships do not have 
professional firefighters but rather rely upon a system of volunteer fire 
companies. In fact, upon examining the not applicable responses (Table 
3), 23% of second-class townships had no opinion on prevailing wage and 
fully 77% of second-class townships found the police collective bargaining 
mandate to be not applicable. This may be a reflection of the small size of 
many 2nd class townships, some of which provide no police protection at all, 
relying upon agreements with other municipalities or upon the state police 
force.



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PAULA A. DUDA HOLOVIAK

Table 3 
Prevailing Wage for Public Works Projects and Police Collective Bargaining 

Mandatory Arbitration (Second-Class Townships)

Mandatory Arbitration Prevailing Wage

Frequency Percent Frequency Percent

Not Burdensome 73 15.8 22 2.9

Moderately Burdensome 161 34.8 44 5.7

Very Burdensome 197 42.6 108 14.1

Total 431 93.2 174 22.7

Not Applicable 31 6.8 592 77.3

Total 462 100.0 766 100.0

So do size and municipal type matter? Do different levels or types of 
municipalities have differing perceptions regarding the burden of mandates? 
Since second-class townships are exempt from some mandates based on 
population size (recycling) or do not offer certain types of services (fire), we 
will examine two incorporated types of municipalities (cities and boroughs) 
and the more densely populated first-class townships to explore differences 
in perceptions based upon municipal type.

Chi-square analysis of the difference among the three groups was 
applied to all 11 mandates studied. In all cases the differences among 
the three types of municipal government (cities, boroughs, first-class 
townships) were statistically significant at the .05 level of significance. 
Table 4 summarizes the results.

Table 4 
Summary Statistics for Cross Tabulations (Cities, Boroughs and First-Class 

Townships)

Mandate Chi-square Probability Cramer’s V

Police and Firefighter Collective 
Bargaining

34.842 .000 .197

Police Certification 26.452 .000 .243

Prevailing Wage 18.383 .005 .143

Tax Exempt Property 61.389 .000 .262

Competitive bidding 25.448 .000 .168

Right- to-Know 20.057 .003 .250

Stormwater and Traffic Control 
Devices

29.281 .000 .180

Separate Bidding Public Buildings 68.576 .000 .277



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LOCAL GOVERNMENT MANDATES IN PENNSYLVANIA

Table 4 
(Continued)

Mandate Chi-square Probability Cramer’s V

Uniform Construction Code 
Certification

13.269 .039 .122

Recycling Requirements 22.604 .001 .158

Publication of Legal Notices 36.222 .000 .252

The strength of the relationship between municipal type and mandate 
rating varies from moderate to fairly strong. Tables 5 and 6 examine the top 
two most onerous mandates as rated by the cities, boroughs, and first-class 
townships

Table 5 
 Police and Firefighter Collective Bargaining Mandatory Arbitration

First-Class 
Township Borough City

Not Burdensome 0% 9.7% 1.9%

Moderately Burdensome 0% 17.5% 11.5%

Very Burdensome 100% 53.4% 86.5%

Not Applicable 0% 19.4% 0%

Table 6 
Prevailing Wage for Public Works Projects

1st Class Township Borough City

Not Burdensome 18.8% 16.5% 13.5%

Moderately Burdensome 6.3% 38.8% 25.0%

Very Burdensome 75% 40.2% 61.5%

Not Applicable 0% 4.7% 0%

Both first-class townships and cities find these two mandates to be very 
burdensome while boroughs find them less so and in some cases even not 
applicable to the daily or yearly functioning of boroughs. Again, small rural 
boroughs have fewer police officers and more part-time officers. Likewise 
small boroughs are less likely to engage in public works projects, which 
trigger the prevailing wage standard (Holoviak 2011).



9

PAULA A. DUDA HOLOVIAK

The large number of properties exempt from real estate taxes due 
to their nonprofit status can cause financial hardships for cash strapped 
municipalities. Hospitals, schools, universities, public charities, and 
churches all require police and fire protection, and other municipal services, 
but they are not required to pay property tax under Pennsylvania law. As 
seen in Table 7, both first-class townships (most of which are 

Table 7  
Properties Exempt from Local Real Estate Taxes

First-Class 
Township

Borough City

Not Burdensome 6.3% 28.2% 9.6%

Moderately Burdensome 12.5% 39.3% 15.4%

Very Burdensome 81.3% 28.2% 71.2%

Not Applicable 0% 4.2% 3.8%

located adjacent to urban centers and are densely populated) and cities find 
this mandate to be very burdensome. Boroughs that tend to be more rural 
are less inclined to rate this as very burdensome.

Discussion: Rethinking the Burden of Mandates

Previous research has indicated that the best approach to the issue of 
local government mandates involves a partnership or collaborative approach 
between state and local government to address the issues of cost estimation, 
cost reimbursement, and best methods for meeting state standards for policy 
and services (Grossback; Zimmerman; Kelly 1994, 1997). In fact, in a 
1995 National Civic Review essay on lessons learned regarding mandates, 
Kelly goes so far as to state that not only are mandates an essential part 
of governing but that local governments do not resist all state mandates 
(Kelly 1995). What the Pennsylvania study has shown is that the burden of 
mandates is really tied to the capacity of local governments to deal with the 
fiscal and administrative burdens generated by these mandates. According 
to the Center for Rural Pennsylvania’s 2014 data, 99% of Pennsylvania’s 
first-class townships are classified as urban while 80% of Pennsylvania’s 
second-class townships are classified as rural. Boroughs are split 56% 
urban and 44% rural. (Johnson 2015). Cities, with larger professional staffs 
and full-time executives, are less likely to see mandates as burdensome 
but more likely to see state requirements such as recycling or police and 
fire arbitration as part of the regular administrative activities of municipal 
government. Similarly, boroughs, which tend to be smaller in population 
and more limited in administrative and governmental capacity, often do not 



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LOCAL GOVERNMENT MANDATES IN PENNSYLVANIA

have to deal with many of these requirements. Boroughs are less likely to 
engage in a series of capital projects or to maintain a large police or fire 
department. 

Likewise, second-class townships who do find themselves subject to 
certain mandates such as police arbitration find them to be very burdensome 
upon their tiny staffs, which often include only three part-time supervisors 
and at best one professional manager and some clerical staff (Holoviak 
2011). Overall, second-class townships often don’t deal with issues such as 
prevailing wage or police certification at all. These mandates simply don’t 
apply to them even if they exist on the legislative books. 

The type of local government caught most in the crosshairs of mandates 
appears to be Pennsylvania’s first-class townships. More densely populated 
and often adjacent to a large urban center, these suburbs and exurbs are 
expected to provide a higher level of municipal services but are restricted 
under Pennsylvania law from expanding their revenue sources. They are 
squeezed at both ends, unable to implement various taxes but required to 
meet all state standards for police, fire, prevailing wage, building codes, 
inspector certifications, etc. 

In conclusion, a one-size-fits-all approach to mandate reform in 
the Commonwealth of Pennsylvania will not address the real impact of 
mandates upon its local governments. Only a targeted approach, taking 
into account the disparate impact of state mandates upon municipalities 
with very different administrative and fiscal capacities and very different 
populations may truly offer mandate relief. Other states that rely on a 
one-size-fits-all approach, such as mandatory legislative review or cost 
estimation requirements, may want to revisit their mandate strategies. In 
Pennsylvania, the Local Government Commission study recommends the 
possible creation of a state level review commission for mandates, similar 
to efforts in other states (Local Government Commission). While this may 
provide some relief, it will only be effective if the review takes into account 
the disparate impact of mandates based upon municipal size and municipal 
fiscal and administrative capacity.

References

Author. May–June 2011. Field Interviews with Pennsylvania Local Government.
Barnett, Jeffrey, Cindy L. Sheckells, Scott Peterson, and Elizabeth M. Tydings. 2014. 2012 

Census of Governments: Finance-State and Local Government Summary Report, 
Economy-Wide Statistics Briefs: Public Sector. www.census.gov/govs/financegen 
(Accessed February 4, 2015).

Gormley Jr., William T. 2006. “Money and Mandates: The Politics of Intergovernmental 
Conflict.” Publius: The Journal of Federalism 36: 523–554.

Grossback, Lawrence J. 2002. “The Problem of State-Imposed Mandates: Lessons from 
Minnesota’s Local Governments.” State & Local Government Review 34: 183–197.



11

PAULA A. DUDA HOLOVIAK

Johnson, Jonathan, Senior Policy Analyst. 2015. Data provided by the Center for Rural 
Pennsylvania, A Legislative Agency of the Pennsylvania General Assembly.

Kelly, Janet. 1997. “Institutional Solutions to Political Problems: The Federal and State 
Mandate Cost Estimation Process.” State and Local Government Review 29: 90–97.

Kelly, Janet. 1995. “Lessons from the States on Unfunded Mandates.” National Civic Review 
(Spring): 133–139.

Kelly, Janet. 1994. “Mandate Reimbursement Measures in the States.” American Review of 
Public Administration 24: 351–373.

Lovell, Catherine, and Charles Tobin. 1981. “The Mandate Issue,” Public Administration 
Review 41: 318–331.

Martin, Lawrence L., and Jenna Cawley. 2012. “The “New Normal” for Local  Government.” 
State and Local Government Review 44: 17S–28S.

State and Local Government Commission. 2012. Senate Resolution 323 of 2010, Study of 
Statutory mandates Placed on Counties and Municipalities (Harrisburg: General 
Assembly of the Commonwealth of Pennsylvania).

St. George, James R. 1995. “Unfunded Mandates: Balancing State and National Needs.” 
Brookings Review (Spring):12–15. 

U.S. Advisory Commission on Intergovernmental Relations. 1990. Mandates: Cases in State-
local Relations. (Washington, D.C.: ACIR).

Zimmerman, Joseph F. 1995. State-local Relations: A Partnership Approach, 2nd edition. 
Westport, CT: Praeger.



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LOCAL GOVERNMENT MANDATES IN PENNSYLVANIA

Appendix A 
First-Class Townships, Boroughs, and Cities Mandate Ratings

Mandate
Not Burdensome Moderately 

Burdensome
Very 

Burdensome
Not Applicable

Frequency % Frequency % Frequency % Frequency %

Police & Firefighter 
Collective 
Bargaining 
Arbitration

38 8.2 73 15.8 265 57.4 86 18.6

Police Certification 
and Training

146 31.6 167 36.1 87 18.8 62 13.4

Prevailing Wage for 
Public Works 
Projects

73 15.8 161 34.8 197 42.6 31 6.7

Property Exempt 
from Real 
Estate Taxes

113 24.5 159 34.4 157 34.0 33 7.1

Competitive Bidding 
and Related 
Advertising 
Requirements

58 12.6 172 37.2 145 31.4 87 18.8

Right-to-Know Law 
Compliance

92 19.9 146 31.6 117 25.3 107 23.2

Stormwater and 
Traffic Control 
Device 
Maintenance 
on State Roads

106 22.9 174 37.7 93 20.1 89 19.3

Bidding 
Requirements 
for Public 
Buildings

151 32.7 168 36.4 31 6.7 112 24.2

Uniform 
Construction 
Code 
Education and 
Certification

122 26.4 205 44.4 114 24.7 21 4.5

Act 101 of 1988 
Recycling 
Requirements

225 48.7 213 46.1 12 2.6 12 2.6

Advertising or 
Publication of 
Legal Notices

101 21.9 144 31.2 40 8.7 177 38.3



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PAULA A. DUDA HOLOVIAK

Appendix B 
Second-Class Townships Mandate Ratings

Mandate
Not Burdensome Moderately 

Burdensome
Very 

Burdensome
Not Applicable

Frequency % Frequency % Frequency % Frequency %

Police & Firefighter 
Collective 
Bargaining 
Arbitration

22 2.9 44 5.7 108 14.1 592 77.3

Police Certification 
and Training

75 9.8 110 14.4 22 2.9 559 73.0

Prevailing Wage for 
Public Works 
Projects

41 5.4 119 15.5 431 56.3 175 22.8

Property Exempt 
from Real 
Estate Taxes

210 27.4 287 37.5 158 20.6 111 14.5

Competitive Bidding 
and Related 
Advertising 
Requirements

58 7.6 267 34.9 400 52.2 41 5.4

Right-to-Know Law 
Compliance

206 26.9 314 41.0 204 26.6 42 5.5

Stormwater and 
Traffic Control 
Device 
Maintenance on 
State Roads

90 11.7 200 26.1 268 35.0 208 27.2

Bidding 
Requirements 
for Public 
Buildings

115 15.0 187 24.4 259 33.8 205 26.8

Uniform 
Construction 
Code 
Education and 
Certification

220 28.7 264 34.5 102 13.3 180 23.5

Act 101 of 1988 
Recycling 
Requirements

219 28.6 204 26.6 51 6.7 292 38.1

Advertising or 
Publication of 
Legal Notices

119 15.5 269 35.1 342 44.6 36 4.7




