Michael Judge, Chair
Commission on Energy Infrastructure Siting and Permitting (CEISP)
Executive Office on Energy and Environmental Affairs
100 Cambridge St., 10th Floor
Boston, MA 02114

Delivered electronically

Dear Chair Judge and Distinguished Members of the Commission,

On behalf of all 351 cities and towns across the Commonwealth, I write to express our appreciation for the work of the Commission and provide input on the Commission’s draft proposal to consolidate clean energy siting and permitting processes at the state and local level.

We deeply appreciate Governor Healey for her foresight to bring stakeholders together to consider potential solutions to challenges found in the siting and permitting processes. The work of this Commission has the opportunity to provide an important foundation for forthcoming policy proposals intended to ensure a smooth transition to clean energy. To each Commission member, thank you for your thoughtful and considerable ongoing engagement with the work of this group.

As you know, significant changes to energy generation, transmission and distribution are needed to help reduce the Commonwealth’s greenhouse gas emissions and meet our climate goals. According to Massachusetts’ Clean Energy and Climate Plan for 2050, 27 gigawatts (GW) of solar development, 23 GW of offshore wind development, and 5.8 GW of storage capacity are needed to ensure adequate electricity supply to support the future lives of Massachusetts residents.

From the Cape to the Berkshires, this new energy development, alongside fortifications of the grid, will touch each community. It is critical that municipalities maintain authority of siting and permitting of clean energy infrastructure (CEI) within their jurisdiction. Municipal officials and residents know the heart of their community — from knowledge of underground utility infrastructure, to stormwater impacts and mitigation, to community preferences for extended environmental protection. Municipalities have the expertise of the local landscape needed to guide clean energy projects through a community acceptance process that will ensure success, community buy-in, and sustainability.

At this juncture, the Commission is considering a proposal to mandate that communities use a consolidated permitting process for smaller-scale clean energy projects. We strongly urge the Commission to instead endorse the MMA’s proposal for a consolidated permitting process at local option. By allowing a local option for municipalities while simultaneously offering incentives for participation, the state will help communities expedite appropriate project approvals while finding efficiencies in the process. Our members are committed to continuous improvement, and by allowing this as an option, municipalities are supported in their efforts to provide innovative and essential services for their residents.

We know that local-option programs work. As a local option consolidated permitting process takes shape with early adopters, additional communities will see the benefits and local officials can get the necessary buy-in from residents. Avoiding a one-size-fits-all mandate allows important flexibility to ensure adoption in communities of all sizes and in all corners of the Commonwealth. The Green Communities Designation and Grant Program, which now boasts 291 participating communities representing 89% of residents in Massachusetts, is an excellent example of the success of an optional state program model that provides guidance, support and resources to municipalities.

The local-option consolidated permitting process must be accompanied by much-needed guidance on health and safety impacts, clarification of key clean energy definitions, and model policies. This guidance should be available to all communities and will support municipal officials to navigate community conversations that inevitably surface during CEI siting and permitting processes. By clarifying common health and safety concerns and utilizing data, the state could clear a path for a simplified process and enriched community understanding of the local and global benefits of CEI development.

Beyond the local-option proposal, we strongly encourage the Commission to ensure that municipalities are engaged early in the siting and permitting process. Municipal advisory opinions must carry weight in the final approval process for CEI projects. Further, municipalities must have the ability to generate community benefits agreements that address the unique needs of their community and offer mitigation to social and environmental impacts that may occur with CEI siting. We further encourage the Commission to address current challenges with slow interconnections under the authority of distribution companies. Consolidating and expediting permitting at the local and state level will not expedite the essential step of interconnecting our new, clean energy resources to the grid and into our homes and offices.

Lastly, while we surely appreciate the Commission’s focus on reducing redundancies in the permitting processes, we strongly recommend that the Commission exercise necessary caution. Redundancies, including providing multiple points for public engagement and input, allow for important opportunities to review plans for social, environmental and safety impacts. These can often be necessary safeguards for both residents as well as the welfare of the planet. Any removal of parts of the process risks reducing the ability of the government to collectively identify and address potential hazards.

The MMA, through our representative, John Mangiaratti, has provided considerable input on the local implications for siting and permitting reform. Additional recommendations have also been offered to the draft proposal, and we look forward to continuing our engagement with fellow stakeholders throughout the work of this important Commission and beyond.

The charge of the CEISP is a significant undertaking, and we are grateful for the dedicated work of Commission members and the staff supporting this essential work. Municipalities are ready and committed partners in the development of clean energy. We are the bridge to residents, the first call that community members make when concerns arise, and essential partners to ensure community acceptance of the clean energy transition. We recognize and appreciate the opportunity to work hand in hand with state government and clean energy stakeholders to ensure a smooth transition to our shared future.

My team and I are available to answer any questions the Commission may have or further discuss the details of the Commission’s proposal. Please do not hesitate to have your office contact me or MMA Legislative Analysts Josie Ahlberg and Adrienne Núñez at jahlberg@mma.org and anunez@mma.org, at any time.

Thank you for your thoughtful consideration of these important reforms, your attention to the needs of cities and towns, and your commitment to ensure a clean energy future.


Adam Chapdelaine
MMA Executive Director and CEO