Public Comment: In Support Of A Temporary Solar Moratorium

Red tailed hawk on solar panels. Photo: Wikimedia Commons

The following public comment was submitted to the Amherst Town Council in writing on February 11, 2022.

I am writing, as a town resident and environmentalist, in support of the temporary moratorium on large-scale ground mounted solar photovoltaic installations (LSGM – Solar) with an exemption for large scale arrays built on parking lots, buildings, brownfields and along a powerline right-of-way. We need to plan first by doing a solar assessment and developing a comprehensive solar array bylaw. And then grant permits for large-scale solar facilities afterwards.

Right now, our zoning bylaw has one sentence on energy facilities—in contrast to five pages of requirements for signs. The Zoning Board of Appeals (ZBA), Planning Director, Building Commissioner and Energy and Climate Action Committee (ECAC) all have stated the critical need for more study and regulation of LSGM Solar). These requests should not be ignored. The ZBA members have been left to assess whether a particular site is appropriate given existing conditions and size of the project, potential environmental impacts on watersheds, groundwater, wildlife, forests, farms soils, wetlands, erosion, neighbors, proper access routes, proper battery storage (which includes the potential for fires), potential leaching of hazardous materials, site vegetation and management, appropriate impacts monitoring, and proper decommissioning, revegetation and disposal of array materials, and site repair.  Nothing in the bylaw addresses offsets or mitigation of farmland or forest loss–and it’s not clear this could be even required under the bylaw. This is far too heavy a lift for the ZBA do project-by-project.

Amherst needs time to develop solar bylaw that reflects community choices made through a solar assessment process that examines the best sites and sizes for solar arrays. This is a legislative decision. We need to ask and answer critical questions: how much solar do we need and where should it go? Does our community want to give up forest and farmland for solar arrays?  What are the best sites for large solar arrays?  How large is too large?  How should the loss of forest land,  farm soils and release of stored carbon be offset and restored after decommissioning?

Getting Amherst to net zero does not mean producing all its energy inside town borders.  Amherst’s green energy plan likely will include using local and regional renewal sources (e.g. community choice aggregation involves buying energy from regional sources).  Since UMass and the colleges use 50% of energy, their plans are critical.  UMass is now developing its plan.  Amherst College has a plan and will be building geothermal facility to heat buildings.  Carleton College already has cut 50% of its carbon-based fuel use with a geothermal energy plant and a windmill.  Amherst also needs time to understand and key into the Commonwealth’s plan for green energy production.  Wind power is New England’s renewable best choice, given our gray weather and strong offshore winds, with other green sources also in the mix:  hydro, solar, geothermal, and hopefully other technologies.

Taking time to do a solar study and draft a proper solar bylaw also will help implement the long-ignored yet critical Amherst Master Plan tasks to:

  1. inventory our natural resources, that include forest lands and farmlands and assess their quality,
  2. decide which forests and farms to protect, and whether to establish a forest reserve and ground water protection overlay district, and
  3. decide appropriate sites for facilities, such as large-scale solar arrays.

We might not be where we are today on solar siting if Amherst had done this work and the Master Plan tasks of creating a committee for siting decisions and disputes mechanism to resolve land use conflicts.

I think the fundamental question for Amherst, as a community and Council is:  How can we get to net zero without destroying our forests and farmlands?

Cutting down forests to build solar facilities is just a bad idea, as is covering Pioneer Valley farms with solar arrays.  Both actions release stored carbon into the atmosphere, end carbon uptake and storage in soils and plants, and wreck crucial resources.  Reforestation is a key climate change strategy everywhere. Deforestation is a cause of climate change. The goal is to plant more trees, not cut them down.

Forests sequester and store carbon dioxide, clean air, produce oxygen, provide food, shelter and corridors for wildlife, protect insect, plant and animal biodiversity, create wood products, reduce temperatures, clean and retain groundwater, prevent runoff and erosion, and provide recreation. Forests also contain fresh water wetlands that sequester and store 10X the carbon dioxide that saltwater wetlands.  Wetlands are critical to wildlife and water protection but it is well established that 100-foot buffer zones are not enough to protect wetlands. Forests now are needed now more than ever for resilience and to temper the impacts of climate change. The call for reforestation and protection of forests to slow or reverse climate change is almost universal.   Goal 1 of the Global Forest Goals Report 2021 by UN Department of Economic and Social Affairs is : “Reverse the loss of forest cover worldwide through sustainable forest management, including protection, restoration, afforestation and reforestation, and increase efforts to prevent forest degradation and contribute to the global effort of addressing climate change.”[1] It’s hard to find a dissenting voice against these goals in the environmental community.

Protecting farmland and increasing local food production also is a climate change strategy – and a key to sustainability. Amherst and the valley have some of the best soils in the state. Even depleted farmland can be revived like at Brookfield Farm, which now feeds hundreds of families locally and in Boston. More farmland is in active cultivation in Amherst than 2 decades ago. Amherst College has started farming its fields and Brookfield Farm has expanded by leasing and now buying fields around town.  Proper farming techniques help soils to retain carbon dioxide. Local food production, especially organic farming, reduces the use of carbon-based fuel for transportation and fertilizers. For example, increasing local food production is a goal of Maine Won’t Wait, that state’s climate action plan.  Only half of the land suitable for farming in Maine is currently farmed.  Maine’s plan  aims to triple the amount of food consumed in Maine from state food producers up to 30% by 2030. Maine also faces increasing farmland loss to large scale solar arrays (see also here) and is examining dual use, that is combining solar arrays with grazing and crops, as a solution.

Forest and farmlands should be the last choice for solar arrays. Built environments, rooftops, parking lots, roadways and brownfields are the first choices.  But unfortunately, state tax incentives and lower construction costs have led to more and more forests and farms being used for large scale solar arrays throughout Massachusetts. Amherst doesn’t have to let state subsidies dictate how Amherst lands are used. We can decide this as a community and a Council.  Town Council can adopt the temporary moratorium–with an exemption for large scale arrays built on parking lots, buildings, brownfields and along a powerline right-of-way.  This will be one step in making critical, long-lasting decisions about our renewable energy plans– and our farm and forest lands.

Finally, in offering this advince I have drawn on my lifelong work in environmental conservation including  work at the Conservation Law Foundation as a Legal Fellow, at Cultural Survival as general counsel, and at  Quabbin Mediation as a mediator.


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