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Our members are the local governments of Massachusetts and their elected and appointed leadership.
Commissioner Mark Sylvia
Department of Energy Resources
100 Cambridge St., Suite 1020, Boston
Re: Request for Information – Green Community Designation and Grant Program
Dear Commissioner Sylvia,
On behalf of the cities and towns of Massachusetts, thank you for the opportunity to offer input regarding the development of the next phase of regulations that will shape the future of the Green Communities program. The Green Communities program, which had the strong support of the MMA during its creation through the legislative process in 2008, has served as an excellent vehicle that has to date helped 110 diverse municipalities in every region of the state reach shared goals in advancing sound energy and environmental practices. We are pleased to offer input on several questions raised in the Department’s Request for Information (RFI) regarding potential changes to the designation criteria that a municipality must meet in order to become a Green Community.
Criterion 1
Designation Criterion 1 requires that a municipality provide for as-of-right siting for renewable or alternative energy generating facilities, research and development facilities, or manufacturing facilities in designated locations. Municipalities may satisfy the requirement by providing as-of-right siting for one type of renewable or alternative energy.
The Department’s RFI asks if a municipality should be eligible for Green Community designation if provides as-of-right siting for one type of renewable or alternative energy, but prohibits another type community-wide, or if the municipality passes a fixed-term moratorium for a specific renewable or alternative energy-generating technology.
Municipalities that create as-of-right siting for one type of renewable or alternative energy are proactively taking a significant step to encourage renewable or alternative development in an appropriate area. In many cases, this decision reflects a well-reasoned assessment of the needs and capacity of the community to host and promote a particular type of energy development. A municipality should not be denied Green Community designation if it prohibits another type of energy development or places a fixed-term moratorium on another type of energy development. These decisions reflect an assessment of the local circumstances unique to each of our cities and towns, and it is not reasonable to suggest that every municipality should be able to accommodate the development of all types of renewable or alternative energy. Similarly, a fixed-term moratorium suggests that a municipality needs time to study a particular type of energy development and the potential impacts on the municipality. Municipalities should in no way be penalized for enacting these measures.
Criterion 3
Designation Criterion 3 requires that a municipality establish an energy use baseline for municipal buildings, vehicles and lighting, and put in place a comprehensive Energy Reduction Plan (ERP) designed to reduce the baseline by 20 percent within five years.
The Department’s RFI asks what should happen after a community has completed five full years and has achieved 20 percent reduction of municipal energy use, mentioning the possibility of a menu of energy targets for municipalities to chose from, as well as the inclusion of other sustainability goals in addition to energy.
A menu of energy targets would allow municipalities to pursue those options that best suit local needs, with a chosen target reflecting what is most relevant or feasible for the community at that point in time. The inclusion of other sustainability goals, which could include water conservation, transportation planning, recycling, and reduced consumption of land natural resources, for those communities that have met ERP targets would be beneficial if the additional goals were presented as part of a menu of options to enable a municipality to choose to pursue a target most relevant or important, based on local conditions.
The Department also asks what should happen if a Green Community has not met its 20 percent energy baseline reduction after completing five years of its ERP. The municipality should not lose its designation as a Green Community, but it should be provided with technical assistance from the Department of Energy Resources in a collaborative process that helps it further its progress. As is noted in the RFI, the comparison to a baseline year can be greatly impacted positively or negatively by factors other than efficiency or conservation measures, including weather and changes to building use. The Department should consider these phenomena when assessing progress.
Funding
Currently, grants for designated communities can be used to fund a wide array of energy efficiency and conservation measures, and may also be used to finance the development of renewable and alternative energy projects on municipally owned land.
The Department’s RFI asks if water savings measures should be eligible for grant funding. Water conservation and water infrastructure are critically important to local governments across the Commonwealth and should certainly be eligible for Green Community grant funds.
Once again, thank you for the opportunity to submit comments on the development of the next round of Green Community regulations, and for the important work you do every day to promote the development of renewable energy and energy efficiency measures statewide. If you have any questions, please do not hesitate to have your staff contact Tom Philbin or Catherine Rollins of the MMA staff at 617-426-7272 at any time.
Sincerely,
Geoffrey C. Beckwith
Executive Director, MMA