From: TK M <tk2828@gmail.com>
Sent: Wednesday, July 24, 2019 4:36 PM
To: RPS, DOER (ENE)
Categories: Has Not Been Sumarized
Dear John Wassam,
Submitted
to DOER:
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 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.
Grid Cluster study:
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 its
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 landmass 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.
This was
written and researched by Steve Grady, but I agree with him
wholeheartedly. We should wait until more research is completed and
better panels and batteries are developed, that would be efficient and would
not create solar abandoned fields of the future.
Thank you
for your attention,
T. McAuley,
Spencer, MA