November 19, 2025 – Between October 17 and November 17, 2025, the Environmental League of Massachusetts submitted comprehensive recommendations to state agencies to shape implementation of upcoming siting and permitting reforms.
Where Massachusetts builds clean energy, and who has a say in those decisions, will determine whether our energy transition is equitable, affordable, and effective. For decades, outdated siting and permitting processes and poor community engagement practices have hindered clean energy deployment, increased costs, and excluded necessary voices.
The 2024 Act promoting a clean energy grid, advancing equity and protecting ratepayers, landmark legislation that ELM championed and helped shape, requires Massachusetts to modernize the state’s clean energy siting and permitting process. These reforms are essential to meeting our climate targets and ensuring our clean energy transition is beneficial for all residents.
Now, ELM is influencing how the state implements this new law. Through coordinated engagement across the Energy Facilities Siting Board (EFSB), Department of Energy Resources (DOER), Department of Public Utilities (DPU), Executive Office of Energy and Environmental Affairs (EEA), and the Office of Environmental Justice and Equity (OEJE), ELM is helping shape how Massachusetts responsibly builds the clean energy infrastructure required to meet its climate mandates. ELM’s latest recommendations build on its work earlier in the year, including our written comments in May on the Healey-Driscoll Administration’s straw proposals for implementing siting and permitting reforms.
“We have a massive opportunity to reform how Massachusetts builds clean energy, and to do so in a way that strengthens communities and advances climate progress,” said Erin Smith, Clean Grid Director at the Environmental League of Massachusetts. “Our recommendations make the most of this moment, not only to increase our Commonwealth’s ambition, but to serve as an example to the nation for getting clean energy siting and permitting right.”
ELM’s efforts are shaping a future where clean energy projects are sited responsibly, evaluated transparently, and developed in partnership with host communities.
Our goal is to develop a system where:
- Clean energy development can be deployed to meet the urgency of the climate crisis: Clean energy will be built on predictable timelines that ensures faster progress towards emission reductions, while ensuring projects are sited and permitted in ways that meet community needs and preserve critical natural resources;
- Clean energy is built where it delivers the most public good: Projects will be steered toward areas with existing grid infrastructure and rights-of-way, reducing land conversion and protecting forests, wetlands, biodiversity, and high carbon-storage areas;
- Environmental justice communities have influence in decisions that affect them: Cumulative impact analysis, stronger community engagement practices, and funding for community participation means voices that have historically not had a say in siting decisions will be empowered to shape projects in their communities;
- Communities hosting energy infrastructure receive benefits: Community Benefit Plans will become best practice, with siting decisions to be informed by how project proponents provide clear commitments, tangible benefits, and long-term accountability to host communities;
- Data, scoring, and decision-making are transparent and accessible: Energy project applicants will be required to disclose how they calculate site suitability scores and agencies will publicly document final siting decisions.
To realize this vision and ensure effective implementation of the 2024 Climate Act, ELM provided specific comments on:
- EFSB’s permitting regulations for “large” clean energy projects: ELM focused on clarifying strong health, environmental, and safety baseline standards for permit approvals, improving documentation of public input, performing effective pre-filing stakeholder engagement; and ensuring robust and data-driven cumulative impact analyses;
- DOER’s permitting regulations for “small” clean energy projects: ELM recommended the reforms be made effective in time for projects to leverage expiring federal tax credits, that minimization and mitigation measures be strengthened, and for more technical assistance to assist municipalities with implementing the reforms;
- OEJE’s Proposed Guidelines for Community Benefit Plans and Agreements: ELM urged for the creation of enforceable, clearly-defined community benefits;
- EEA’s Proposed Site Suitability Guidance: ELM emphasized the critical role of biodiversity protection, climate resilience, and cumulative impact considerations; and
- DPU’s Proposed Regulations on the Intervenor Support Grant Program: ELM advocated for a program that enables accessible community participation in a broader range of proceedings.
While separate from the 2024 Climate Act reforms, ELM also provided specific recommendations on:
- DOER’s Draft Model Bylaws for Solar and Storage Systems: ELM supported efforts that simplify the process for municipalities to responsibly accelerate clean energy deployment.
Massachusetts agencies involved in implementing these reforms expect to review submitted comments through early 2026, with a goal of promulgating the regulations by March 1, 2026, and full implementation by July 1, 2026.
As Massachusetts implements the siting and permitting reforms outlined in the 2024 Climate Act, ELM remains a driving force ensuring these changes support climate ambition while strengthening communities and protecting our Commonwealth’s natural assets. ELM is committed to working alongside policymakers to align regulations and climate goals, helping build the foundation that will guide clean energy deployment for decades to come.
We thank agency partners across the Healey-Driscoll Administration for their ongoing collaboration and dedication to our clean energy future.
