Comments you can reference - DOER solar and battery draft guidelines due March 13th 5:00 pm
Janet Sinclair
Hello Friends
Here is a sample letter to DOER related to permitting solar ( along with some other "green" energy generation ) 25 Megawatts and under ( which is pretty much all solar development) and batteries energy storage systems ( BESS) under 100 Megawatts.
Comments are due March 13, 2026 at 5:00 pm. Please use these ideas however you want. Please add any thoughts, embellish ideas, and delete what you don't agree with. We are hoping to make sure that DOER has ample feedback. Background is below.
Body of the e-mail-
To the Department of Energy Resources,
Please consider my comments on the Draft Guidelines for Small Clean Energy Infrastructure Facility Siting and Permitting ( 225 CMR 29.00).
Our cities and towns are the first line of protection for our public health and environment. This is well established in Massachusetts, with its history of local control that has acknowledged that local boards are the experts on local conditions and are most expert in regulating, siting and permitting industry, housing, open space, wetlands, private wells, septic systems, and other land uses. The proposed guidelines for Small Clean Energy Infrastructure Facility Siting and Permitting leave little room for towns to regulate and site "small' solar and battery storage projects.
These are my comments related to ensuring that municipalities have clearer ability to protect the health, safety and welfare of our communities.
The municipalities should not be subject to the Dover Amendment for solar projects or any battery storage that is not for the onsite use of residential, commercial or industrial properties. The Dover Amendment was never intended to be related to the commercial and industrial scale solar projects that are being proposed and built in Massachusetts. The Dover Amendment is simply unrelated to stand alone Battery Energy Storage Systems (BESS). The draft guidelines and various final regulations reference the Dover Amendment often as the standard that needs to be met. The Amendment is profoundly vague, and it appears that the Department of Energy Resources (DOER) will use it to arbitrarily short-circuit local concerns, as we have seen with the Attorney General's Office and the courts. Instead, guidelines should have clear language.
If the site suitability score is high enough to warrant mitigation, the municipalities should retain the option of rejecting the project.
DOER needs to be explicit about what local zoning is allowed that is more strict than the model bylaws for solar and BESS.
Setbacks for solar and BESS should not be tied to a municipality’s setbacks for other industrial uses in the town as suggested by DOER, as most large scale and problematic solar and batteries are often sited in non- industrial zones, making those setbacks irrelevant.
Towns should be able to have siting standards not already listed by DOER and the Energy Facilities Siting Board for building permits for stand-alone BESS up to 99 MW. For permitting and regulating, towns should be able to consider air contaminant dispersion modeling, proximity to schools, churches, hospitals, residential nursing facilities, and other public buildings where evacuation would be challenging and where there are vulnerable human populations. Standards should also protect ground water, drinking water supplies, all properties related to food production, and land for protected wildlife and biodiversity. Towns should be able reject projects where air pollution from fires would impact those properties and communities.
Each municipality should be able to use a calculation of the “as of right” or of the built environment potential solar build-out in the towns to assess their potential contribution for the Massachusetts solar deployment goals when evaluating commercial or industrial solar and battery projects. DOER and the Energy Facilities Siting Board should acknowledge that potential when considering permitting or appeals.
Each municipality should be able to limit how much forest is destroyed for solar or batteries.
Each municipality should be allowed to pursue a goal of available farmland devoted to growing food, and to disallow solar and batteries on specific properties such as prime farmland, or amounts of land devoted to food production and other agricultural products.
Massachusetts should explicitly disallow land to be converted from Article 97 protection for solar and battery siting.
Massachusetts should explicitly disallow conserved farmland from being taken out of those programs for siting energy projects, and continue its policy for solar siting on agricultural properties.
Each municipality should be able to have an upper limit on the amount of commercial or industrial solar in their towns.
The appeal process for permitting decisions should include a panel of independent experts to evaluate impacts on wetlands, hydrology, property values, agricultural productivity, noise, forest products and productivity, climate, public health, impacts on sensitive populations, wildlife protection and biodiversity, real estate values or other considerations if requested by the towns.
Each municipality should be able to be funded by the state or by developers to pay for hazard prevention and costs for safety related incidences caused by BESS.
Losses of property values should be compensated for by the developers or the state with a simple, timely and user friendly process, similar to a property insurance claim.
DOER Public Information and comment details:
Background
https://www.mass.gov/info-details/clean-energy-siting-permitting-regulations
DOER on January 21, 2026 published updated draft guidelines.
Written Comments
DOER is now accepting public comments on the draft guidelines. Comments may be emailed to DOER.Siting...@mass.govor mailed to:
Division of Clean Energy Siting & Permitting, c/o Rick Collins, Director, 100 Cambridge Street, 9th Floor Boston, MA 02114
The deadline to submit comments on the guidelines is March 13, 2026.
View the public comments received on the draft regulation.
Or mail to:
Division of Clean Energy Siting & Permitting
c/o Rick Collins, Director
100 Cambridge Street, 9th Floor
Katherine Harrelson
Done. Thanks for the body text!
LoriOn 03/09/2026 9:13 AM EDT Tribal Scribal <lio...@gmail.com> wrote:An untold number of forests and trees will fall due to bad policy and ignorance.Please add your voice to this......
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********************************"Our planet's future climate is inextricably tied to the future of its forests." - Oct. 5, 2018 letter from 40 scientists to the Intergovernmental Panel on Climate ChangeWith that in mind, checkout my latest "It's the Trees"More writing here:https://devolutiondays.blogspot.com/
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WolfChildren Life
I plan to add in the following sentences to my comments:Each municipality should be able to decide if they want to site solar or batteries on their aquifer or in the watershed of their drinking water supply.Massachusetts should specifically disallow solar and batteries to threaten drinking water supplies.Thank you for putting this together, Janet.
On Mon, Mar 9, 2026 at 9:37 AM 'LORI BRADLEY' via Trees As A Public Good <trees-as-a-public-good@googlegroups.com> wrote:
Done. Thanks for the body text!
Lori
On 03/09/2026 9:13 AM EDT Tribal Scribal <lio...@gmail.com> wrote:
An untold number of forests and trees will fall due to bad policy and ignorance.Please add your voice to this......
---------- Forwarded message ---------
From: 'Janet Sinclair' via ResponsibleSolarMA <responsiblesolarma@googlegroups.com>
Date: Mon, Mar 9, 2026 at 9:06 AM
Subject: Comments you can reference - DOER solar and battery draft guidelines due March 13th 5:00 pm
To: responsible solar <responsiblesolarma@googlegroups.com>
Hello Friends
Here is a sample letter to DOER related to permitting solar ( along with some other "green" energy generation ) 25 Megawatts and under ( which is pretty much all solar development) and batteries energy storage systems ( BESS) under 100 Megawatts.
Comments are due March 13, 2026 at 5:00 pm. Please use these ideas however you want. Please add any thoughts, embellish ideas, and delete what you don't agree with. We are hoping to make sure that DOER has ample feedback. Background is below.
Janet SinclairFor Responsible Solar Massachusetts
E-mail to: DOER.Siting.Permitting@mass.gov
DOER is now accepting public comments on the draft guidelines. Comments may be emailed to DOER.Siting.Permitting@mass.govor mailed to:
Division of Clean Energy Siting & Permitting, c/o Rick Collins, Director, 100 Cambridge Street, 9th Floor Boston, MA 02114
The deadline to submit comments on the guidelines is March 13, 2026.
View the public comments received on the draft regulation.
Email comments to: DOER.Siting.Permitting@mass.gov
Or mail to:
Division of Clean Energy Siting & Permitting
c/o Rick Collins, Director
100 Cambridge Street, 9th Floor
--
You received this message because you are subscribed to the Google Groups "ResponsibleSolarMA" group.
To unsubscribe from this group and stop receiving emails from it, send an email to responsiblesolarma+unsub...@googlegroups.com.
To view this discussion visit https://groups.google.com/d/msgid/responsiblesolarma/1411832001.6601007.1773061583585%40mail.yahoo.com.
--
********************************"Our planet's future climate is inextricably tied to the future of its forests." - Oct. 5, 2018 letter from 40 scientists to the Intergovernmental Panel on Climate ChangeWith that in mind, checkout my latest "It's the Trees"More writing here:https://devolutiondays.blogspot.com/
***************************************
Checkout The Enviro Show podcasting anytime at:Broadcasting on WXOJ-LP, 103.3fm. Northampton, MA, Tuesdays, 6pm
Webstreaming at: http://valleyfreeradio.org/listen/
Also on WMCB, Greenfield; 107.9, Mondays & Tuesdays at 6pm. Streaming at http://wmcb.net/Listen.html
[Blog w/links and YOUR comments at: http://envirosho.blogspot.com/ ]
Email: envir...@valleyfreeradio.org
***************************************
--
Please use this list to provide new information, meeting, and action announcements. Please stay on topic and be constructive. Please start a new email thread for new topics.
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You received this message because you are subscribed to the Google Groups "Trees As A Public Good" group.
To unsubscribe from this group and stop receiving emails from it, send an email to trees-as-a-public-good+unsub...@googlegroups.com.
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Please use this list to provide new information, meeting, and action announcements. Please stay on topic and be constructive. Please start a new email thread for new topics.
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You received this message because you are subscribed to the Google Groups "Trees As A Public Good" group.
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To view this discussion visit https://groups.google.com/d/msgid/trees-as-a-public-good/157331519.107307.1773063416984%40connect.xfinity.com.
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You received this message because you are subscribed to the Google Groups "ResponsibleSolarMA" group.
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Eric C Lintala
Sent: Monday, March 9, 2026 9:06 AM
To: responsible solar <responsib...@googlegroups.com>
Subject: Comments you can reference - DOER solar and battery draft guidelines due March 13th 5:00 pm
You received this message because you are subscribed to the Google Groups "ResponsibleSolarMA" group.
Eric C Lintala
Sent: Monday, March 9, 2026 2:17 PM
To: LORI BRADLEY <lorib...@comcast.net>; ResponsibleSolarMA <responsib...@googlegroups.com>; Responsible Solar Massachusetts <responsible-sol...@googlegroups.com>
Cc: Tribal Scribal <lio...@gmail.com>; Trees As A Public Good Network <trees-as-a-...@googlegroups.com>
Subject: Re: Fwd: Comments you can reference - DOER solar and battery draft guidelines due March 13th 5:00 pm
Rita Renee Toll-Dubois
Eric C Lintala
Sent: Thursday, March 12, 2026 2:49 PM
To: responsib...@googlegroups.com <responsib...@googlegroups.com>
Subject: Re: Comments you can reference - DOER solar and battery draft guidelines due March 13th 5:00 pm
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