RENEW Northeast has submitted formal comments to the Massachusetts Energy Facilities Siting Board (EFSB) on proposed draft regulations to implement the 2024 Climate Act Siting and Permitting Reforms.
The Climate Act created a single consolidated permit process intended to streamline approvals for clean energy infrastructure, reduce development timelines, and help the Commonwealth meet its ambitious climate and energy goals. In our comments, RENEW expressed appreciation for several provisions in the draft regulations while identifying areas where adjustments could improve efficiency and avoid unintended project delays.
Supporting Strong Siting and Community Benefit Provisions
RENEW commended the EFSB for incorporating earlier recommendations on site selection narratives and recognizing the social and environmental benefits of clean energy projects in site suitability scoring. These measures help ensure that projects delivering tangible community benefits are given appropriate consideration.
Concerns About Completeness Determinations
We cautioned that the proposed completeness determination process could unintentionally extend project timelines beyond the statutory deadlines. To address this, RENEW recommended the development of a clear completeness checklist to provide certainty for project proponents and prevent unnecessary delays.
Pre-Filing Engagement Should Be Flexible, Not Prescriptive
RENEW supports meaningful community engagement before filing permit applications but stressed that “one-size-fits-all” timelines could hinder rather than help the process. The final regulations should:
-
Treat pre-filing timelines as guidelines, not rigid requirements
-
Allow flexibility for diverse project types and community needs
-
Avoid duplicative filings, such as overlapping checklists and notices
-
Provide interim guidance to “grandfather” projects already underway, preventing the need to restart engagement processes unnecessarily
Avoiding Unnecessary Alternative Site Engagement
We also flagged concerns that some provisions could require developers to evaluate and engage communities on alternative sites after a preferred site is selected. This would add cost, time, and complexity—sometimes without securing property rights—potentially derailing viable projects.
Commitment to Collaboration
RENEW remains committed to collaborating with the EFSB, stakeholders, and communities to ensure the Climate Act’s permitting reforms achieve their intended purpose—speeding the deployment of clean, reliable, and affordable energy resources.
“The Climate Act was designed to streamline the clean energy permitting process. We want to ensure the final rules keep that promise, while still supporting robust community engagement and environmental stewardship,” said Nathan Raike, RENEW’s Manager of State & Local Affairs.