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Ms. Cinda Jones

W.D. Cowls, Inc.

PO Box 9677

134 Montague Road

Amherst, MA 01059

May 17, 2015

Dear Ms. Jones,

We the undersigned represent the Alliance for Appropriate Development. We are writing

because based on the currently available information, we will be impacted by the proposed

Wheelock Tract Solar Development that is being considered for development on land owned by

W. D. Cowls.

To be clear, we are generally supportive of solar energy and solar farms, but in this instance we

have concerns about the appropriateness of this particular project. We are giving serious

consideration to opposing a proposal if this development is submitted as presented. In order to

advance transparency and to increase the availability of information about this project, we ask

that W.D. Cowls and/or the developer, Lake Street Development, provide us with timely written

responses to questions outlined below regarding our specific issues and concerns.

Two of the signers of this letter attended the May 4, 2015 presentation by Mr. Shane Bajnoci

who provided information on the project on behalf of W.D. Cowls. We want to go on record as

stating that notice to abutters about this meeting was insufficient; most residents received a letter

in the mail on or about May 1, only days before the meeting. Additionally, the map of the project

which was noted in the mailing was not included nor was this error corrected later, since no

copies were provided to the public at the May 4 meeting. We raise these concerns because we

believe that any subsequent process must allow for ample notification and full disclosure of

information.

CONCERNS

Overarching Concern

1. Our concern is that this project may not be appropriate for the site nor is it clear whether there

are notable benefits for the town or residents of Shutesbury given the disturbances in will create.

Most notably, this project seems inconsistent with the stated goals set forth in the 2008

Shutesbury Zoning Bylaws. These goals include: “the protection of large contiguous tracts of

forest land to maintain commercial forestry as a viable agricultural activity; the protection of

water in the watersheds that supply drinking water to Amherst, Massachusetts, the Boston

metropolitan area, and the Town of Shutesbury; the maintenance of a rural road system that

includes many miles of unpaved roads; the protection of significant wildlife habitat in a healthy

forest ecosystem”. This project seems to threaten or substantially alter all of the above goals.

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We believe that much information needs to be provided before we or the town can make an

informed decision about this project. We ask that W.D. Cowls and Lake Street Development

provide written responses to the following questions by June 3, 2015. We have numbered each

item and request that your response include numbers that coincide to the questions/issues raised.

Water and wetlands

2. What are the expected impacts on the existing wetlands? (Mr. Bajnoci claimed there were no

wetlands but we believe this is incorrect).

3. Has there been an independent survey of vernal ponds in the area and if not, when will this

be completed and the findings made available to the public?

4. What will be the expected impact on residential drinking water wells and the underlying

aquifer?

5. What will be the expected impact on the drainage in and around Reed Road, in particular

water diverted by the development out of its natural streambed and the increase in water

volume resulting from deforesting of 30 acres of wooded land?

6. What size escrow account will be created to address the possible need for a resident to dig a

deeper well or sell their home if the change in water flow creates problems that cannot be

mitigated?

Road buildup and construction

7. What will be required in terms of road construction to enable Reed Road to support the

necessary truck and construction equipment used during all phases of the project?

8. What will be the impact of road construction on Pratt Corner Road in order to yearlong

access for maintenance vehicles?

Electrical transmission

9. What will the requirements be for the electrical transmission lines to carry electricity from

this 6 megawatt project to the electric grid at the bottom of Pratt Corner Road? Will new

lines need to be erected and if so, what size and capacity will they be?

10. What will be the impact on digging a trench down Reed Road to Pratt Corner Road to carry

the electricity from the solar farm site?

11. Mr. Bajnoci stated at the meeting that none of the electricity generated will go to Shutesbury

but rather will be sent to a municipal housing authority. What municipal housing authority

will be the recipient of this energy and if it is not known, how will this be determined?

12. Is it accurate to say the energy generated by this project will be added to the electric grid and

will not reduce the needs of Shutesbury?

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Wildlife Conservation

13. What independent surveys have been conducted to document the disturbance of wildlife

habitat ranging from large mammals such as moose, to smaller mammals and birds, to frogs

living in the vernal pools? If no survey has been conducted when and how will this be done

and how will it be paid for?

Finances

14. What are the taxes that Shutesbury can expect to receive from this project? A figure of

$8,000 was mentioned at the meeting; this seems a very small amount given the cost of the

project.

15. On what basis will taxes owed to the town of Shutesbury be determined? If zoned as light

industrial will this project be taxed as equipment or a power plant?

16. Mr. Bajnoci indicated that the life of the installation is 25 years. If the assessed value of the

installation will depreciate over the 25 year life span of the equipment, what is the estimated

tax schedule that shows the decreasing taxes that Shutesbury will receive?

17. What infrastructure charges (construction and on-going maintenance) will Shutesbury

taxpayers be expected to cover on behalf of this project?

18. Mr. Bajnoci mentioned that after the 25 year life of the project, the installation will be

decommissioned. How much money will be put in escrow prior to construction to enable full

restoration of the land following decommissioning? Where and how will this money be held

and who will control its release?

Precedent

19. This installation would potentially be sited in the Rural Residential zone of Shutesbury,

requiring a Special Permit. However, as noted, this installation goes against the stated goals

of the Shutesbury Zoning Bylaws. What assurance is there that once a light industrial

installation is allowed in a Rural Residential area, that W.D. Cowls will not return with

another request for additional installations, noting that the contiguous woodland, watershed

protection, etc. have already been compromised?

ALTERNATIVE SITES AND MODELS

As stated at the outset of this letter, we firmly believe that solar development is a good thing and

communities should embrace renewable energy projects. However, we similarly believe that

there are good and bad projects and that some projects advance the public good while others

prioritize private profit with less public benefit.

We believe that any solar farms installed in Shutesbury should prioritize the following values:

Be municipally owned or at least directly benefit the town and residents of Shutesbury in terms of finances, energy offset, etc.

Be built to a scale that is appropriate to the land/community, not the requirements to make a project financially viable for investors

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Minimize the impact and degradation to woodlands and water systems

Establish a sustainable precedent rather than a precedent for additional installations that

further contradict the goals of Shutesbury’s zoning bylaws

Given our support for solar energy and solar farms, we propose several alternate projects/models

for a solar installation in Shutesbury. We request a written response by Cowls as to why these

alternative approaches to solar development are not more appropriate and more closely comply

with the zoning bylaws for Shutesbury.

A. Option 1: Develop a solar farm under the transmission lines at the bottom of Pratt Corner

Road, as proposed several years ago.

Benefits: the land here is already deforested and currently used for high capacity

electrical transmission. There is minimal environmental degradation from construction

and little distance for any electrical lines.

B. Option 2: The developer buy-out, with approval of owners, nearby tracts of land that are

already in commercial use on non-woodland plots.

Benefits: If supported by commercial landowners, non-wooded tracts could provide a

similarly sized solar farm without needing to cause environmental degradation in terms of

woodlands, water systems, etc.

C. Option 3: By town vote several years ago, Shutesbury has a Municipal Lighting Plant.

This allows for a publicly owned and operated utility. Such a utility could contract for

smaller, more appropriately sited solar farms within Shutesbury with terms being

negotiated with the developer so that the electrical and financial needs of the town and

residents of Shutesbury are met.

Benefits: Installation will be governed by Town of Shutesbury and will directly benefit

the town and residents. This will allow for smaller, more site-appropriate installations.

COMMUNITY MEETING

We will be convening a community meeting to present information on the Wheelock Tract Solar

Development to other residents, landowners and allies impacted by this potential project. The

meeting will be on June 17, 2015 in Shutesbury, location to be confirmed. This meeting will be

open to the public but it will not be an official meeting of town government.

We invite a representative of W.D. Cowls and Lake Street Development to attend the meeting.

You will be provided with 10-15 minutes of time to share information about the above concerns

or any other pertinent aspects of the project. We require that any information that is shared at this

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meeting by your representatives be provided in written format in a quantity suitable for a

moderate sized group.

Thank you for your timely response to this letter. Your written responses can be sent to:

Alliance for Appropriate Development

c/o Suter

94 Pratt Corner Road

Shutesbury, MA 01072

alliance.appropriate.devo@gmail.com

Sincerely,

Members of the Alliance for Appropriate Development

Michael Suter Andrew Webster

Rob Hayes Andrea Cummings

Roger Tincknell Randi Silnutzer

Jane Costello Miriam DeFant

Julie Stepanek Gian DiDonna

Lucy Gertz Michael DeChiara

Harvey Rivard Rob Kibler

Cc: Shutesbury Town Administator

Shutesbury Conservation Commission

Shutesbury Zoning Board of Appeals

Lake Street Development