From: Steve Grady <ssgrady4@gmail.com>
Sent: Wednesday, July 24, 2019 10:13 AM
To: RPS, DOER (ENE)
Subject: Pollution of Massachusetts by solar PV
Attachments: attachment 1.pdf
Categories: Saved as HTML
Good
morning,
Why
do we hate solar? My iPad will run out if memory before I finish.
The difficult part when composing this comment was trying to remain
civil. Covering 1/3 of the land mass of Massachusetts with solar PV
"TO SAVE THE EARTH"! Really!
Dear
RPS Stakeholder,
The
Department of Energy Resources (“DOER”) wishes to notify stakeholders that the
deadline to provide written comments on the proposed changes to the RPS Class I
(225 CMR 14.00) and RPS Class II (225 CMR 15.00) Regulations has been extended
to 5 PM
on July 26, 2019. Please submit written comments
on the proposed changes to the RPS Class I and RPS Class II regulations to John
Wassam electronically to DOER.RPS@mass.gov or
via mail to the Department of Energy Resources, 100 Cambridge Street, Suite
1020, Boston, MA 02114.
Copies
of the proposed regulations may be obtained from the DOER website www.mass.gov/doer or
by contacting DOER at DOER.RPS@mass.gov.
Department
of Energy Resources
Submit to DOER:
John Wassam
Department of Energy Resources
100 Cambridge St, Suite 1020
Boston, MA 02114
This is an official
comment regarding the DOER RPS regulations. As more of the landscape is
covered with solar arrays more people are taking interest. It should be
no surprise to the DOER that after a little research citizens oppose
solar. Coal & Oil do pollute the air while Solar PV arrays pollute
the land. They constrain wildlife, kill environmentally essential
vegetation and are TAX EXEMPT!
The towns of
central Massachusetts are especially burdened when a solar company, such as
Zero Point Solar promote the tax benefit of installing solar and request a
chapter forty-fifth tax exemption simultaneously!
The DOER suggestion
that the towns negotiate Payments in Lieu of Taxes instead of receiving the
full amount that all other legitimate businesses are required to pay
demonstrates just how distant the DOER policy is from reality.
Pilots were
originally set up for Non-Profits - 501C3 NON-Profits. Towns that accept
PILOTS are agreeing to substantial losses - giant coupons where they are not
deserved. Your Solar Industry does not need these tax incentives to
survive.
Link to
forty fifth: https://www.energycleantechcounsel.com/tag/clause-forty-fifth/
The DOER should
subsidize research & development NOT destroying the countryside with TAX
EXEMPT solar arrays. Consider that, 225 CMR 14.08 (3) (d) 1. Commercial
Development, uses the word "development" not "deployment".
The UMass Amherst campus is proud of it's Combined Cycle natural gas
facility. The DOER should develop a solar & wind solution that
replaces the fossil fuel at that campus before destroying the rest of
Massachusetts. Central Massachusetts is NOT just a place to install
solar, it is home to nature and hard working people.
UMass
utilities link: https://www.umass.edu/physicalplant/utilities-0
Since 2003
Massachusetts 225 CMR 14.07 has forced the utilities to buy ever increasing
percentages of solar energy while 225 CMR 14.08 allowed the utilities to make
alternative compliance payments. Then the Massachusetts Energy Diversity
Act of 2016 forced ISO-NE to consider political policy over electrical
engineering realities.
Renewables, such as
solar, rely on variable, unpredictable weather conditions to produce variable,
unpredictable electricity. The DOER RPS regulations that force the
construction of solar arrays also force utilities to buy this electricity and
absorb the cost of leveling out it's disruptive characteristics.
National Grid has
instituted a "cluster study" to solve the problems forced upon the
grid by hastily implemented DOER policy. The grid was not designed to
function as a battery for intermittent solar.
The DOER continues
to mask the true cost of grid scale batteries that will be passed onto all
ratepayers in the near future.
Utility
Scale Battery Costs: https://pv-magazine-usa.com/2019/01/02/utility-scale-solar-power-plus-lithium-ion-storage-cost-breakdown/
Every technology
has it's limitations. Generating electricity from solar requires
replacing SQUARE MILES of Massachusetts' green, self renewing trees with solar
arrays. The Massachusetts Clean Energy Center website has 8 years of data
on Massachusetts solar PV systems documenting a capacity factor of only
13.35%. If the DOER covered the entire land mass of Massachusetts with
solar it would only function 3 hours 12 minutes daily, and there would be total
weeks and multiple days with NO electricity at all from these solar arrays!
In the years to
come Massachusetts will be heavily dependent on Natural Gas and CO2 emissions
will be higher than today.
Capacity
Factor link: https://www.masscec.com/data-and-reports
Capacity
vs Energy: https://www.iso-ne.com/about/what-we-do/in-depth/capacity-vs-energy-primer
Burning lots of
natural gas will be the ultimate outcome of the current DOER policy. Batteries
may solve part of this issue but will never allow the retirement of fossil
fueled generators. Battery technology is currently 4 hours, yet weeks of
storage will be needed before dismantling installed fossil fueled generation.