91 
ments can satisfy only specific, identified needs of the new community, 
and those needs will be met most adequately only where their provision 
is in the perceived area-wide interests of A and B. Although C will be 
represented on the governing councils of both A and B, those bodies 
meet separately with the result that an exclusive reliance on inter- 
governmental contracts to meet C’s ongoing needs will leave C without 
any means to express them as a separate entity to a governing body 
capable of responding to them. The paralysis latent in such a situation 
is entirely unacceptable for a new community of any substantial size. 
Metropolitan government 
The third alternative solution to new community boundary problems 
then is some form of metropolitan government in which the interests 
of the new community as a functional, independent whole would be 
given consideration along with those of the municipalities within 
whose boundaries the new community lies. This kind of metropolitan 
government could not deal with the new community only by discrete, 
voluntary agreements reached from time to time on narrow issues. 
Consequently, metropolitan administration by council-of-govern- 
ments, for example, would be inadequate because it is strictly advisory. 
Although the council might provide for representation from the new 
community as a separate entity, the effect of council action still 
would be just to recommend, not to require, that the duly constituted 
municipalities within the council region act on issues pertinent to the 
new community. 
On the other hand, a true, compulsory metropolitan government, in 
which the interests of A, B, and C are represented and balanced 
according to the needs of the entire area, runs into severe practical and 
legal problems in Massachusetts. Perhaps the most convincing prac- 
tical problem is that the creation of such a metropolitan government 
at the very least would require special legislation by the general 
court; *° while equipping it with the compulsory powers necessary to 
override the will of individual municipalities on some issues might 
require an amendment to the home rule provisions of the constitu- 
tion.*® Because the likelihood of achieving even the first piece of 
legislation is remote, the creation of any kind of metropolitan govern- 
ment to assist new community development in Massachusetts is 
equally remote.” 
Annexation 
The fourth possible alternative to meeting the boundary require- 
ments of an overlapping new community is annexation. Strictly in 
terms of its physical effect on boundary lines, annexation would mean 
the inclusion of the entire new community site within the boundaries 
of one municipality and the concurrent excision from the contiguous 
municipality of that part of the site originally fallmg within it. For 
equally strong legal and political reasons, achieving annexation of a 
new community is virtually impossible in Massachusetts today. 
“18 Massachusetts Constitution am. art. 89, sec. 8(3). 
136 Tbid. The nature of the ‘‘metropolitan or regional entities’”’ envisioned by the home rule amendment is 
not clear, although the wording ofsec. 8(3) makes it evident that the cities and towns encompassed by it are 
not meant to be superseded by the entity with respect to those charter adopting powers granted to them by 
sec. 2. Of course, a “regional entity’’ could be created without an amendment by dissolving municipalities 
A and B under sec. 8(4) and reincorporating the entire area, but the new entity thus created is not a metro- 
politan government in the generally understood sense of the term. 
137 Even the utilization of existing county units as partial metropolitan governments is unlikely, given the 
~weakness and narrow functions of county units and the nonconformity of county lines with existing metro- 
Politan areas in the commonwealth. Intermunicipal Relations, supra note 8, at 25-27. 
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