Massachusetts Department of Energy Resources (“DOER”) will finalize by July 15 regulations doubling the size of MA SMART solar photovoltaic program from 1,600 to 3,200 megawatts (MW). On the surface this is a reasonable, if limited, step forward.
But like most things, the devil and long-term consequences are in the details.
Unless changed by DOER, or the legislature, the latest version of SMART erects strong barriers to moving effectively toward 100% renewable power in the long run, and will cost many renewable jobs, and millions of investment and tax revenue in covid-19 times.
There are significant flaws cloaked within the regulations doubling the size of SMART.
Embracing the proposed DOER regulations will:
- Hamstring and slow down the Baker-Polito plan for 100% carbon neutrality,
- Help keep solar as a small fraction of the power grid and protect the status quo and the fossil fuel based utility business model;
- Continue to keep MA farms free of dual-use solar projects choking off a desperately needed income stream that could save farmers from selling their land for development;
- Apply land use restrictions risking halting development of nearly 70 solar projects totaling over 475 megawatts;
- Continue the policies of requiring solar developers pay for upgrading utility feeders and substations, instead of developing a plan for building and financing the infrastructure needed ASAP for a renewable power – storage grid;
- Regard large scale solar development, appropriately regulated, as a threat to the Commonwealth rather than a gateway to good jobs, strong local economies, and ecological survival.
- Politely ignore the fact that each year the failure to slash carbon-dioxide emissions through renewables and efficiency rapidly increases the prospects for devastating effects of climate changer on our Commonwealth.
- Completely negates the enormous amounts of available land in much of the state that’s suitable for ground mounted PV development that could be used as a basis to easily get to 100% renewables very quickly and effectively.
First, DOER’s regulations expand the ineligible land use category adding three new GIS layers “Priority Habitat,” “Core Habitat” and “Critical Natural Landscape” applicable to any PV site where 50% of land is in this category. This means that 2 million acres, 40% of MA land, must remain solar free. Combined with other existing restrictions, 90% of MA land will now have zero ground mount solar
Second, ground mounted solar in remaining areas is forbidden from all farmland under 61A tax abatement rules unless approved as agricultural PV under special SMART regulations which to date have stopped almost all so called dual-use PV development on MA farms.
Dual-use allows farmers to continue to use their land to farm while integrating solar PV on poles, canopies or vertically mounted dual-facing translucent PV panels. This breakthrough technology, developed by Next2Sun in Germany is coming soon to MA for the benefit of farmers.
https://www.next2sun.de/en/homepage/
Third, the Agricultural PV rules and their shading analysis tool does not recognize the existence of dual-facing translucent PV panels or indirect solar which is the basis of much of their performance as well as growth of row crops and pasture.
Fourth, whatever ground mounted solar installations above 500kw will exist are subject to a steep “greenfield subtractor” further reducing the ability to finance ground mounted solar arrays.
Currently, in Massachusetts, 4,284 solar jobs, representing 52 percent of the solar workforce, are expected to be lost through June 2020 due to COVID-19, according to MA Solar Energy Industry Association (SEIA).
Added to this will be millions of dollars already spent on large ground mount projects that will be scrapped, or, at best, converted to much smaller agricultural solar installations, if the DOER will ever regularly approve such systems.
DOER’s new SMART rules keeps the status quo in command, harms prospects for quick renewable development, fails to help farmers, risks throwing away 475 megawatts of projects, more jobs, and tax revenues.
The new SMART is a place holder. A new administration in Washington will certainly launch a Green New Deal in some fashion that will lead sooner or later to new state action.
But there is every reason not to wait and pretend that the global climate crisis is not upon us and requires prompt, determined and comprehensive action. The new SMART rules, while a step forward, embrace a mindset similar to what we believed about covid-19 until March 2020, that the deleterious consequences will affect other less fortunate people in another place, it certainly could not happen here.
It’s time to protect our farms and futures.
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Roy Morrison builds solar farms. www.RenewableSunPartners.com
Fact Check
Area of MA for 100% solar
Renewable Energy Transformation is Now a Simple Choice by Roy Morrison
In MA , total electric consumption is 52.5 billion kWh. That’s 43,740 megawatts solar at MA solar generation rates of 1.2 million kWh per megawatt. That means a total of 205 square miles of solar panels, a 14.3 miles square.
MA SMART Emergency Regulations Joint Comments SEIA, CCSA, NECEC, MassSolar, SEBANE, & Vote Solar June 1, 2020
See Page 5 land restructions
http://www.communitysolaraccess.org/wp-content/uploads/2020/06/Joint-MA-SMART-ER-Comments-6.1.20.pdf
Next2Sun dual facing translucent PV panels mounted vertically
https://www.next2sun.de/en/homepage/
SOLAR MASSACHUSETTS RENEWABLE TARGET PROGRAM (225 CMR 20.00) GUIDELINE Guideline Regarding the Definition of Agricultural Solar Tariff Generation Units
https://www.mass.gov/doc/draft-agricultural-solar-tariff-unit-guideline/download
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