TA Blog: Green Communities Program comments
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The MA Department of Energy Resources invited public comments on its proposed guidelines for qualifying and administering the new Green Communities program. Below are comments submitted by the TA on January 26, 2009 on behalf of the Town of Littleton. The Green Communities Act provides up to $10M annually in grants and loans for communities that qualify as a Green Community as specified in the Act. | TO: Green Communities Division, DOER FROM: Town of Littleton The following are submitted as comments on the Division's draft guidelines for qualifying and administering the Green Communities Program. The Town of Littleton is a Municipal Light Plant (MLP) community which desires to fully explore the steps necessary for MLP communities to qualify for the Green Communities Program. In so doing, the Town needs to be able to clearly articulate to our local electric ratepayers the financial benefits of becoming a Green Community-- particularly at the cost of imposing the 0.5-mill per kwh MTC surcharge as the price of admission. The Division's assistance with doing a cost-benefit analysis for MLP communities to qualify will greatly enhance those communities' participation in the program, and the Division should make such technical assistance an early priority. In addressing climate change and global warming, the Green Communities Act ought not to freeze out municipal light plant communities-- even if that requires legislative amendment. The establishment of an energy use baseline is an important and necessary prerequisite for certification, but it should require significant and early resources from the Green Communities Division to all interested cities and towns. The ICLEI Cities for Climate Protection program has an excellent software program available to its members for conducting a baseline emissions inventory and forecast. While ICLEI is a membership-fee driven program, perhaps the Commonwealth could establish with ICLEI an "associate member" category for all cities and towns in Massachusetts, with membership funded by the Commonwealth through the Division. The baseline energy survey must be made as easy as possible in order for municipal officials to do it and be able to keep up with it. The Division should coordinate communities' efforts at data entry/quality control through community service efforts from area colleges and graduate schools. The Division should act as a clearinghouse for communities' procurement of alternative fuel and fuel-efficient vehicles. In making inquiries now for vehicle purchases in the new fiscal year, we are informed that hybrid police vehicles, for example, are not available through the state purchasing office. This is an unacceptable disconnect between the goals set forth in the Green Communities Act and the practical application of those goals. The Town of Littleton is an expedited permitting community under MGL C.43D, and has designated two Priority Development Sites under that economic development program. The expedited permitting standards under MGL C.43D are reasonable and appropriate for expedited permitting under the Green Communities Act. In order to encourage regional cooperation-- noting that bonus points are awarded for applications consisting of more than one community-- the Division should clearly identify what the basis for multi-town coordination is expected to be in a joint application. Ideally, all cities and towns-- without exception-- should become Green Communities, with all of us moving forward simultaneously, mutually supported by each other and by the Commonwealth. It should be the Division's mission-- and the Commonwealth's-- to make it so. Thank you for your consideration. Keith A. Bergman Town Administrator Town of Littleton, MA
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