From:	Adam Beal <adam@lhadvisers.com>
Sent:	Wednesday, October 12, 2016 3:52 PM
To:	SREC, DOER (ENE)
Subject:	Comments on DOER Next Generation Solar Incentive Straw Proposal

Dear Commissioner Judson,

Lighthouse Advisers is a real estate development consultancy that works with solar energy developers 
on projects nationwide.  To date, we have served a number of key clients on dozens of solar projects 
developed within the Commonwealth of Massachusetts in the past four years.  

We write to you today to commend DOER on its leadership in putting forth yet another proposal to 
further the development of renewable energy, specifically solar, in the Commonwealth.  With few 
exceptions, in our opinion, the details outlined in the September 23, 2016 Next Generation Solar 
Incentive Straw Proposal are well thought out and fair to all concerned.

However, we also write to express our objections regarding proposed project siting restrictions outlined 
in the proposal.  Specifically, these are:

1.       The proposed restriction on siting projects on land designated as "forest land" under 61A.  We 
cannot see a readily-available means of predetermining as to whether or not a particular parcel 
has been so designated, including through the state’s OLIVER GIS system.  In practice, we 
believe one would have to run a title search on every proposed project site prior to undertaking 
a site control effort to determine whether or not such a designation exists on the subject 
parcel.  This would be an extremely cumbersome undertaking, increasing the time and soft costs 
required to secure proposed project sites.  And while we are not necessarily condoning 
deforesting otherwise forested land for purposes of solar facility development, it does remain 
worth mentioning that solar has been shown to generate a net positive carbon impact 
compared to forested land, offering a net positive atmospheric carbon reduction in only 2 – 3 
years when replacing trees.

2.       The proposed restriction on siting projects in BioMap 2 Core Habitat and Critical Natural 
Landscape, as this restriction would eliminate nearly 40-50% of otherwise buildable land in 
western MA and 50-60% in the southeast, Cape, and the islands.

3.       The proposed restriction on projects sited on soils with a Prime Farmland designation.  We have 
yet to find any studies showing that a temporary 20 – 30 year use as a solar facility poses a long-
term negative impact to soil quality.

The siting restrictions proposed by DOER, when taken as a whole, will have the effect of drastically 
reducing land available within the Commonwealth for solar project development, invariably driving up 
solar land prices considering the laws of supply and demand, as developers will have far fewer sites from 
which to choose.  Also, identifying and securing project sites will become a much more time-consuming 
endeavor for solar developers under these restrictions, further increasing project soft costs.  When 
coupled with the overall declining incentive as compared to the SREC II program, these siting restrictions 
amount to a substantial further decline in the incentive.

In addition, we believe it to be inappropriate for the state to restrict a private land owner from 
maximizing value on his or her land by putting it to its highest and best economic use simply because his 
or her land is designated as Prime Farmland, BioMap 2 Core Habitat or Critical Natural Landscape, or as 
"forest land" under 61A.  As an alternative, if the state has an interest in preserving Prime Farmland, it 
might better buy or lease such land rather than overreaching restrictions on private property owner 
rights.  

Thank you for your timely consideration of these comments as you work to finalize the program.

Best regards, 

Adam Beal 
Principal 
Lighthouse Advisers 
 
Utility scale and distributed generation renewable energy project development.  
 
adam@lhadvisers.com | www.lhadvisers.com | (970) 379-3937 cell | (970) 315-0357 fax

