Speak Out This Week: SMART 3.0 Public Hearings and Comment Deadline

There are still two important actions to take this week to make sure our forests, farmland, and communities are protected from harmful solar development under the proposed SMART 3.0 regulations.

1) Attend a Public Meeting on SMART 3.0 – Thursday and Friday

There are three opportunities to share your concerns about the updated solar subsidy regulations, SMART 3.0:

• Thursday, July 24 at 2:00 PM – Virtual

• Thursday, July 24 at 6:00 PM – Virtual

• Friday, July 25 at 1:00 PM – In person at Greenfield Community College, Stinchfield Lecture Hall, Room N335

We are hoping to have a big turnout in Greenfield. Join us outside starting at noon with signs! The press will be covering the event.

2) Submit Written Comments by Friday, July 25 at 5:00 PM

Even if you attend an event, we encourage you to also send a written statement.

📧 Email comments as attached PDFs to: DOER.SMART@mass.gov
🕔 Deadline: Friday, July 25 at 5:00 PM

Background

The notice of the filing can be found [here]. These regulations affect all of us. It is critical that SMART 3.0 does not continue to provide huge financial incentives to solar development in highly inappropriate locations — such as forests and productive farms.

Talking Points

We recommend personalizing your message using the concerns raised in our recent meetings:

• These regulations allow for and encourage solar on productive and prime farmland.

• These regulations allow for forests to be clear-cut for solar.

• What is disallowed for solar in forested land is insufficient — critical natural landscape areas in BioMap3 should be off limits for projects not attached to a residence or business.

• The adders meant to encourage solar on the built environment are not enough to shift development away from forests and farmland.

• The adders for rooftop solar do not cover the additional costs, so they are not a strong enough incentive.

• The “mitigation” fee for harmful solar is not quantified and may not prevent environmental harm.

Sample Message

Sample Draft Message:

To:  

DOER.SMART@mass.gov 

Subject: SMART 3.0 Public Comment
To Whom It May Concern,

I am writing to express my concerns regarding the SMART 3.0 solar regulations. While I appreciate the efforts to expand solar energy, several aspects of these regulations raise environmental and economic concerns that I believe need to be addressed to ensure a balanced approach between renewable energy development and environmental conservation.

1. Forest Clear-Cutting:
Allowing forests to be clear-cut for solar projects runs contrary to the principles of environmental sustainability. The restrictions on solar development on forested land are insufficient, particularly when it comes to critical natural landscape areas identified in BioMap3. These areas should be protected and exempt from solar projects unless they are attached to a residence or business.

2. Solar Development on Farmland:
The regulations currently permit and even encourage solar installations on productive and prime farmland. This practice risks a significant and often substantial loss of crop yields, as the cultivation of crops in or under solar panels can dramatically reduce agricultural productivity. A more effective strategy should be implemented to ensure the preservation of our vital farmlands.

3. Insufficient Incentives for Built Environment Solar:
Although adders are in place to encourage solar installations in built environments, they fail to significantly deter solar projects on invaluable forest and agricultural land. Furthermore, the adders for rooftop solar do not adequately cover the additional costs associated with these installations, thereby not providing enough incentive to prioritize rooftop solar over large-scale projects.

4. Vague Mitigation Fees:
The introduction of mitigation fees for environmentally harmful solar developments is a step in the right direction. However, the current framework is too vague and lacks the specificity needed to effectively protect environmental interests and prevent inappropriate solar development.

On a positive note, I commend the improvements made to facilitate the participation of lower-income residents in the SMART program through increased subsidies. This is a crucial step in ensuring equitable access to renewable energy benefits.

In conclusion, while the aim of the SMART 3.0 regulations is admirable, I urge you to reconsider these concerns to foster a more environmentally sound approach to solar energy development. I look forward to seeing revisions that more effectively balance solar expansion with the preservation of our critical land and water.

Thank you for considering my comments.

Sincerely,

[Your Name]

[Your Address]

Learn more at https://www.responsiblesolarma.org/