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!

 

Deadline to Provide Written Comments 

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.

 

 

Steve Grady

email: ssgrady4@gmail.com

Cell: 508-450-4654