DOAG: INPUT SOUGHT ON DRAFT REPORT ON “ENERGY SPRAWL” AFFECTING FARMLAND, FORESTS



                                                            
January 12, 2017


INPUT SOUGHT ON DRAFT REPORT ON “ENERGY SPRAWL” AFFECTING FARMLAND, FORESTS

 

      HARTFORD – The state Council on Environmental Quality (CEQ) is seeking input on a draft report aimed at finding ways to stimulate solar energy facilities in Connecticut in places other than farms and forests.

            The draft report, Energy Sprawl in Connecticut: Why Farmland and Forests are Being Developed for Electricity Production, documents the surge in proposals to use farmland and forest for the construction of large solar electricity-generating facilities.

            This article is adapted from the report, which is available for review and comment at www.ct.gov/ceq.

            The trend toward placement of solar photovoltaic facilities on farmland and forest is accelerating, with 1,600 acres selected and/or approved in 2016, up from 200 acres in 2015.

            The report notes the irony in the state’s spending millions of dollars to preserve agricultural and forest land and to encourage private forest management and conservation while, with another hand, encouraging conversion of similar lands into electricity-generating facilities.

            Until the past decade, housing and commercial development were the biggest sectors converting land out of agriculture. The acreage of land used for agriculture remained fairly steady during and after the recession that began in 2007.

            It now appears that development of energy facilities is the largest single factor driving land out of agriculture. While agricultural landowners may benefit financially from selling or leasing land for energy production, other farmers lose leased acreage essential to their business.

            Connecticut long ago concluded that support of the agricultural sector and conservation of productive land was worth state investment. And the simultaneous pursuit of two state goals which appear to be in conflict is often portrayed as a balancing act.

            Unfortunately, the “balancing” approach usually results in the diminishment of both pursuits. In the case of renewable energy and the conservation of land – two goals in which the state has invested much – the solution is to integrate or harmonize the two,  finding a way to stimulate the development of renewable energy on appropriate sites while continuing policies that conserve productive lands.


            Some of the draft report’s conclusions include: 


· In an average year, the state preserves about 1,700 acres of farmland and forest land. In 2016, the area of farmland and forest selected by the Department of Energy and Environmental Protection and/or approved by the Connecticut Siting Council for development of solar facilities nearly equaled that amount.

· Connecticut is unprepared to guide the placement of solar facilities to minimize their environmental damage.

· There are two decision points where state agencies influence the location of utility-scale solar facilities: DEEP’s selection of facilities to supply Eversource and United Illuminating with electricity from renewable sources, and the Connecticut Siting Council’s approval of the facilities.

            The draft report calls the Siting Council’s approval “nearly automatic” because of outdated statutes.

             “As a state working hard toward a sustainable economy, we should not be pitting solar energy against agriculture and forests,” said CEQ Chairman Susan Merrow. “We can have green power and green farms and forests, but we need to find ways to steer the power facilities toward industrial properties and other previously-developed land.”

            The report states that while the solar industry continues to grow in Connecticut, not all solar installations yield equal benefits. Solar panels on commercial rooftops, industrial lands and old landfills can be sustainable “home runs.” And laws that encourage utility-scale solar facilities should remain in place but be corrected.

            Achieving Connecticut’s goals for stability, efficiency, land conservation, economic opportunity, health and happiness requires more than a fixation on the lowest price for a commodity. To choose a supplier solely because its product is the cheapest ignores the costs that its production imposes elsewhere in the economy.

            In the case of solar photovoltaic generation, widespread use of farmland and forest is likely to result in several costs that should be considered in decision making, including:

· The reduction in available farmland and consequent rent increases;

· The loss of jobs in agriculture and forestry;

· The continued costs of carrying brownfields and under-utilized lands that could be hosting energy facilities if those facilities were not built on green fields;

· The additional costs of making up lost progress toward the state’s goals for Connecticut Grown food and wood;

· Ecological costs such as habitat fragmentation and destruction.

            Drawing on hindsight and five years of other agencies’ experiences, the CEQ has identified two critical deficiencies and offers several recommendations.

            Deficiency A: Current selection criteria value short-term price above all else:

          DEEP selects renew-able energy projects which promise to deliver electricity at the lowest cost while effectively excluding environmental siting considerations and long-term indirect costs.

            Energy facilities are no exception to the general rule guiding development. It is nearly always cheaper to build on agricultural land and clean forest land than it is to remediate a parcel that might be contaminated or in some way complicated by previous land uses.

            As a result, the solar facilities are directed by the market to farmland and forest land and away from previously-developed land.

            Recommendation 1 (Concept): State agencies should not encourage developments that consume agricultural land or forested land.

            The Council is not recommending that agricultural or forest landowners be prohibited from leasing their land to energy producers; the Council intends to offer recommendations affecting agency actions.

            Recommendation 2: Solar developers should realize substantial incentives if they use previously-developed land. Details to be determined.

            Deficiency B: Regulatory approval of solar utility-scale photovoltaic facilities is nearly automatic. The Connecticut Siting Council, required to approve solar facilities by declaratory ruling, cannot deny approval for a solar photovoltaic facility no matter how many acres of farmland, forest or wildlife habitat (outside of wetlands) will be eliminated. Municipal regulation is pre-empted.

            Recommendation 3: To be determined.

            The public is encouraged to submit ideas and comments until January 18, and the CEQ expects to discuss the report further at its January 25 meeting, scheduled for 9:30 a.m. at the Department of Energy and Environmental Protection, 79 Elm Street, Hartford.

     The Council on Environmental Quality submits

Connecticut’s annual report on the status of the

environment to the Governor pursuant to state statutes. It also publishes special reports and makes recommendations for legislation to correct environmental

problems, and investigates citizens’ complaints and

allegations of violations of environmental laws.