To the Editor:
The last letter discussed the ramifications of the stretch building code requirement for the Green Communities designation for Marion. A stretch building code can be voluntarily adopted by a majority vote of the Town Meeting. The purpose of a stretch code is to promote energy efficiency in Town construction projects by imposing stricter and more rigorous building standards. Adopting such a building code replaces personal decision-making on how green to build by governmental edict on how green you will build. Cost increases of three to six percent can be expected as the result of the stricter building standards. This not only impacts the cost to Town residents but also Town capital construction costs, including the cost of affordable housing. Replacement value insurance coverage gaps may develop as the result of the cost difference between base building and stretch building code cost of replacement. Green building insurance endorsements may be required for some homeowner’s policies. Insurance cost increase with a green premium.
Marion will also be required to develop and implement a five-year 20 percent energy reduction plan. Energy reduction programs usually require capital spending. The Marion Energy Management Committee “EMC” has done no comprehensive staff work to identify the areas of reduction and the capital and other costs required to implement the 20 percent reduction targets. Once again an EMC cost benefit analysis is lacking to justify Marion joining the Green Communities program.
A vehicle management and purchase program needs to be implemented as one of the five Green Communities qualifying criteria. The Town is required to purchase fuel-efficient replacement vehicles. The Town would not be allowed to recycle the police cars now used as utilities vehicles as is the current practice. The Building Inspector, Department of Health, Assessor’s office and DPW all use recycled police cars. This means the police department’s fleet could not be recycled and would result in approximately $140,000 in additional fleet purchases costs in future years.
Green Communities’ administration costs are significant and would burden the Town’s small staff. First, a baseline energy report needs to be completed. This becomes the baseline to measure the 20 percent energy reductions for the five-year cost reduction target and corresponding progress-reporting period. All the energy-use data for each and all Town facilities, vehicles and the school needs to be compiled including electricity, gasoline, fuel oil and propane. This data is then entered in to a Massachusetts Department of Energy “DOE” model that converts the usage to a single BTU platform for measurement. The DOE estimates a minimum of 500 hours are required to complete this baseline repot. The Town’s administrative cost for this work absent any grant availability can be expected to be approximately $25,000. Annual administrative reporting of the energy reduction achievement targets to the DOE for the five-year reporting period can reasonable expected to be approximately $35,000 or more in the aggregate. Any changes to Town facilities such as the Town House project must be submitted to the DOE for approval. Any grant money received would require incurring additional administrative expenses to hire a program manager to oversee any grant expenditures.
Availability of Green Communities’ grant money is predicated on the Town qualifying for the Green Communities’ designation. The Town then submits qualifying projects to the State in a competitive competition with other qualified communities for grant money. The total statewide grant pool is limited by statute to $10 million. Grant eligible projects are limited to specific Green Communities’ criteria. Marion, because of its small size, will not have many grant qualifying projects. This means expected grant money will be rather limited with regard to the cost incurred to qualify for a Green Community designation. The EMC has made no attempt to quantify this cost burden and the grant award breakeven point, which may range from $300,000 to $500,000. Yet, the EMC’s agenda is to push for material zoning changes to permit “as a matter of right zoning” with expedited permitting for commercial solar farms in Marion and push the adoption of a stretch building code in order to qualify for the Green Communities designation.
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