SMART Review

» DOER Presentation on SMART Review

These are our initial take-aways from the first SMART review hearing in Lenox. Please use these thoughts as  you see fit, but please do not just copy and paste. Redraft in your own words and add any thoughts you see as appropriate.

The deadline to submit comments was extended to September, 27th, 2019 and can be submitted electronically at:, with the subject “400 MW Review Public Comments.”

Let’s make the “SMART” program truly smart!

The Massachusetts Department of Energy Resources (DOER) says on their website:

“DOER created the Solar Massachusetts Renewable Target (SMART) Program to create a long-term sustainable solar incentive program that promotes cost-effective solar development in the Commonwealth.”

Our answer – The “smart” program is not cost-effective.  No more of our money going to giant, out-of-area corporations – that is not our definition of “cost-effective”! Be truly smart – support our local solar installers who provides good, local jobs and support our local economy.

The cap in western Massachusetts was met instantly – that is not equitable! And that is not “long-term sustainable solar incentive”.  While the proposed changes address this, the current proposal to raise the cap 800MW seems short-sighted and will likely slow solar growth yet again.

No more of our money going to cut down intact forests! Representatives of these giant corporations come into our area calling our forests “underutilized” land and telling us what a tiny fraction of the entire state land is being cut down for solar. Our response – don’t even consider cutting down our air-cleaning, carbon-sequestering forest until you have built on every suitable rooftop, over every possible parking lot, and covering every brownfield.

We do not want a “greenfield subtractor”, we want a greenfield PROHIBITION!

Do not grandfather projects in the pipeline that would cut down our forests. These should be re-directed to already disturbed lands.

We appreciate a pollinator adder if it specifies locally native plants are to be used.

State energy efficiency programs are failing in western Massachusetts and especially failing income-eligible consumers. Going door-to-door in an Income & Minority Environmental Justice neighborhood in Pittsfield, we found that over half the occupants reported never having heard of MassSave. This just shows what a poor job the state programs are doing in reaching our western Massachusetts income-eligible neighborhoods. Maximizing energy efficiency will minimize the amount of energy infrastructure build-out needed.

We do appreciate the broader definition of low income to include Income Environmental Justice neighborhood, assuming that people outside of these neighborhoods who qualify for R-2 (low income) rates still qualify as well.

Community Shared Solar Systems are not actually solar systems if they sell their RECs they are selling their solar attributes. They must not be allowed to then advertise to consumers that they are selling “solar” electricity. They sold the right to say that.

Be truly “smart” – support:

  1. rooftop solar on every building with good exposure
  2. solar over every parking lot – if Logan airport can do this on the top floor of their parking garage, we can do it here!
  3. Solar on brownfields, old landfills, etc.
  4. benefits to local contractors to make homes solar-ready – replacing old roofs, adding support to existing roofs, upgrading wiring/circuit breakers
  5. Big storage at every electric grid substation so parts of the grid can function independently – preferably non-toxic, iron-flow batteries.
  6. Require every big-box store to retrofit to add solar on their roof & parking lot
  7. Require all new construction to be net zero energy