by Emma Foehringer Merchant
July 06, 2020

Sally Pick lives in Montague, Massachusetts, a town of under 9,000 residents in the western part of the state. It’s made up of five smaller villages established among forest and farms and is also home to the Montague Plains Wildlife Management Area, a conserved region of rare pine plains.

In addition to sitting on the town’s energy committee, which worked to reduce Montague’s overall energy use 20 percent from 2008 levels through energy efficiency initiatives, Pick works as an environmental consultant and volunteers with Climate Action Now Western Massachusetts, a group that supports 100 percent renewable energy in the state. But she’s watched with dismay as developers have planned more and more solar installations around Montague.

Over the last several years, as solar capacity grew exponentially in Massachusetts, towns and counties in lesser-populated western and central Massachusetts have become increasingly anxious about the resource’s impact on the region’s land.

“There’s a lot of concern among towns in this whole area that have a lot of forests about the potential for a huge amount of development,” Pick told Greentech Media.

That concern has come to the fore in discussions on the state’s keystone distributed solar program, SMART, which regulators recently proposed increasing in the capacity supported from 1.6 to 3.2 gigawatts.

In addition to growing the program, regulators added financial disincentives for projects on undisturbed land in efforts to shift more solar development to previously developed sites, large commercial rooftops and parking structures. Solar developers say the shift in incentives will eliminate nearly 500 megawatts of planned development, while conservation groups argue regulators haven’t gone far enough.    

There has long been tension between renewables development and environmental conservation. But that conflict is more complex in the case of SMART regulations, because solar development is specifically designed to fight climate change and advance the state’s environmental goals. That leaves Massachusetts in a tricky spot: balancing land-use concerns, climate action and its vision for an electric grid with high amounts of distributed solar.

What the state’s Department of Energy Resources (DOER) decides could define the fate of Massachusetts’ healthy distributed solar market and its role in the state's ambitious climate goals. Massachusetts has plans to reach 35 percent renewables by 2030 and slash greenhouse gas emissions 80 percent below 1990 levels by 2050. In addition to distributed solar, it will seek to lean on offshore wind, storage, hydro and energy conservation to get there.

Balancing solar ambitions with conservation goals

Regulators proposed numerous changes to the SMART rules, but much of the controversy surrounds two pieces of policy on land use: first, DOER suggested increasing the “greenfield subtractor,” a per-kilowatt-hour-per-acre sum that reduces incentive compensation for projects on undeveloped land. Regulators also expanded the territories where that subtractor applies, using land categories that encompass about 90 percent of the state, according to an analysis from trade group the Coalition for Community Solar Access and solar developer Borrego Solar.  

Neither environmental groups nor developers are entirely happy with those proposals.

In a Greentech Media analysis of public comments submitted to DOER, 29 groups of solar developers, lawmakers and energy and farming trade organizations urged the department to loosen those restrictions, which they say will stunt solar growth. Borrego told Greentech Media in May that the new restrictions would disqualify 80 percent of its pipeline in the state. BlueWave Solar said in comments that 55 percent of its portfolio would be made ineligible for SMART incentives.

Farmers, who may lease unused land to developers, also expressed worry about losing that income source under the new requirements.

“Many farms look to put less productive parts of their land under solar to provide year-round income as a means of keeping the rest of the farm viable,” wrote 24 state representatives, the Massachusetts Farm Bureau, the Cape Cod Cranberry Growers' Association, the Massachusetts Association of Dairy Farmers and the Massachusetts Forest Alliance in joint comments. They argue the land-use change “essentially eliminates a tool that could be used in the long-term protection of farmland.”

Recently, most solar development in central and western Massachusetts — where there is more space and less population — has occurred on “undeveloped land,” including acreage tied to agriculture. About three-quarters of PV systems developed from 2013 to 2018 in three western Massachusetts counties, including the one where Montague is located, were sited on previously undeveloped land, according to a 2019 analysis from the Harvard University Forest program. Just 4 percent were mounted on buildings and parking structures, the type of projects DOER hopes to encourage. Researchers estimated that PV development took place on 84 acres of agricultural land and 92 acres of forest land in those counties each year during that period.

Twenty conservation groups, town planning boards, state lawmakers and small energy developers contended in public comments to DOER that the land-use restrictions should be significantly strengthened, or at least maintained to protect against more development on forested and undisturbed land. Organizations including the Appalachian Mountain Club and the Massachusetts Land Trust Coalition argued for an even greater increase to the greenfield subtractor — 5x rather than the proposed 2.5x  — and a broader application of the subtractor to a solar site’s land.

No easy answers for solar in Massachusetts

Balancing the competing interests is a challenge because both land conservation and solar growth fall under the state’s environmental goals. Forests sequester and store carbon, while solar offsets emissions. Separate comments from national environmental organizations the Sierra Club and the Nature Conservancy dodged a hardline stance on land-use issues. Instead, the Sierra Club suggested DOER “recognize the nuanced nature of the debate and resist blanket policy that does not recognize the varied land situations.”

The Department of Energy Resources declined to comment on concerns about land use.  

Questions about the emergency regulations come amid greater uncertainty for distributed solar developers working in Massachusetts. A swath of utility-led studies on interconnection solar projects has led to months of delays for many developers and high upgrade costs for a few. The coronavirus pandemic has presented further complications, delaying permitting and slowing project timelines. Massachusetts has lost 4,200 solar jobs out of a national total over 60,000 jobs lost, according to the Solar Energy Industries Association.

Aside from land use, commenters on SMART regulations raised other concerns, including the definition of low-income customers and the low percentage of projects set aside for those consumers; the attachment requirements for energy storage; and whether projects serving public offtakers like municipal agencies should be able to avoid the greenfield subtractor, even if their project is on private land. (You can read all the comments here.)

After releasing the regulations April 14, DOER has 90 days to finalize them. Based on that timeline, the department will decide on the changes by mid-July.