Mark Mühlhaus / Windwärts Energie GmbH

We read the CT Viewpoints commentary “No net loss!’ Don’t’ cut down forests to build solar sites” published on Dec. 1 with interest. We here at Rivers Alliance of Connecticut, a nonprofit environmental advocacy group committed to protecting all the waters of Connecticut, sent a letter to the Department of Energy and Environmental Protection (DEEP) requesting that Commissioner Katie Scharf Dykes impose a moratorium on solar development on agricultural and forested land until adequate guidelines for siting are established.

Petition 1425 to which Ms. Langhorne and Ms. Hoffman voiced opposition illuminates the flaws in our current process of siting large scale solar. Environmental protection demands that we find a balance between competing resources. When we consider a renewable energy such as large-scale solar, we need to balance the value of reduction in greenhouse gasses with carbon storage/sequestration and other eco-system services of soil and forest resources. We need to look at an economic model for solar that takes all the externalities into account.

The Governor’s Council on Climate Change (GC3) is leading a new, bold effort that builds on our mitigation goals to reduce greenhouse gas emissions and create a clean energy future for our state. It also acknowledges that we are already experiencing impacts from climate change and the importance of adaption planning for a resilient future. Additionally, the GC3 recognizes the importance of the ecosystem services provided by our agricultural lands and forests for mitigation and adaptation, something that previous climate change planning in Connecticut did not consider.

At the same time, our General Assembly and Public Utilities Regulatory Agency are both conducting hearings related to the resiliency of our utilities and our current electric grid. It is recognized that we need both centralized and distributed generation to build a modern grid with the resiliency needed to adapt to climate change. Current policies reward utilities and their stakeholders for large scale construction projects effectively steering utilities away from distributed generation.

Given the number of applications for large scale solar currently before the Siting Council, Rivers Alliance has requested that DEEP to put a moratorium on large scale solar on agricultural land and core forests until the Siting Council reviews the recommendations from the GC3 and, in coordination with DEEP, adopts new standards for review. In 2017, a bill was enacted to protect prime farmland and core forests. It is evident, however, that we are still losing farm and forestland to solar development at an alarming rate. The GC3 working groups have identified critical ecosystem services provided by our natural and working lands that are not addressed by the legislation and are not being considered by DEEP or the Siting Council.

Another important factor must be taken into consideration is environmental justice. We need to look at policies that discourage and preclude bringing distributed generation and its many benefits including net metering to those who need it most and have been discriminated against in our infrastructure policies. Make no mistake about it, this is a matter of social and racial equity.

The Department of Energy and Environmental Protection must adopt policies and procedural changes that balance conflicts between large-scale solar, agricultural lands and core forests, as well as social and racial equity.

Alicia Charamut is Executive Director of  the Rivers Alliance of Connecticut.

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