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THE MASSACHUSETTS DEPARTMENT of Energy Resources will finalize by July 15 regulations doubling the size of the MA SMART solar photovoltaic program from 1,600 to 3,200 megawatts. 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 percent renewable power in the long run, and will cost many renewable jobs and millions of investment and tax revenue in this period of COVID-19.

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 percent 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 to pay for upgrading utility feeders and substations instead of developing a plan for building and financing the infrastructure needed as soon as possible 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 energy efficiency rapidly increases the prospects for devastating effects of climate change on our Commonwealth.
• Completely negates the enormous amounts of available land in much of the state that’s suitable for ground-mounted photovoltaic development that could be used as a basis to easily get to 100 percent renewables very quickly and effectively.

DOER’s regulations expand the ineligible land use category, adding three new layers — priority habitat, core habitat, and critical natural landscape — applicable to any photovoltaic site where 50 percent of land is in this category. This means that 2 million acres, 40 percent of the land I the state, must remain solar free. Combined with other existing restrictions, 90 percent of Massachusetts 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 photovoltaic under special SMART regulations which to date have stopped almost all so called dual-use PV development on state 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 Massachusetts for the benefit of farmers.

Third, the agricultural photovoltaic rules and their shading analysis tool do not recognize the existence of dual-facing translucent photovoltaic 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 500 kilowatts 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 the Massachusetts 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, harm prospects for quick renewable development, fail to help farmers, and risk throwing away 475 megawatts of projects, 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.

Meet the Author

Leadership team, Renewable Sun Partners

It’s time to protect our farms and futures.

Roy Morrison builds solar farms as part of the leadership team at Renewable Sun Partners.

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