From:	Lauren Sinatra <lsinatra@nantucket-ma.gov>
Sent:	Friday, October 28, 2016 3:52 PM
To:	Judge, Michael (ENE)
Cc:	SREC, DOER (ENE); Libby Gibson; Madden, Timothy - Rep. (HOU); Gregg 
Tivnan
Subject:	Nantucket Comments: Current Design Considerations for the Next 
Generation Solar Incentive

Importance:	High

Dear Mr. Judge:

Please accept the following comments regarding the Current Design Considerations for the Next 
Generation Solar Incentive.  I wish to raise several concerns related specially to the proposed 
Land Use & Siting Criteria and the Nantucket Load Share Apportionment Block. I also offer a 
suggestion for an additional add-on tariff for consideration, which could help promote solar 
growth in low-saturation, priority utility distribution areas.

As you may know, there are many unique challenges to successfully developing solar on 
Nantucket, most of which can be attributed to the island’s remoteness.  As an island Town and 
County, Nantucket is strictly limited in our available land area.  As a result, there is a lack of 
developable land, which comes at a premium cost and is subject to competing local interests. The 
island’s geographic location 30-miles off the coast of Cape Cod naturally increases project 
construction costs by up to 50%.  Not only are solar development costs higher because of special 
transportation and travel logistics, but also because of the difficulty of securing reasonable 
insurance policies since all Nantucket projects are located in extremely high wind zones and 
within 1-3miles of the ocean. 

However, Nantucket has an especially compelling need to develop solar energy, as recent 
National Grid energy forecasts show Nantucket’s peak load growing five times the statewide 
average.   Due to this significant load growth, Nantucket has been targeted by National Grid for a 
Non-Wires Alternative project to help defer a costly and disruptive third undersea transmission 
cable through traditional and alternative peak reduction strategies—among them being the need 
for increased renewable energy (along with battery energy storage systems).  

In reviewing the proposed “Land Use & Siting” criteria, we are strongly opposed to the inclusion 
of a “Priority Habitat” prohibiting restriction, as we believe it will have the unintended 
consequence of disqualifying all meaningful solar projects within the entire island of Nantucket 
for the foreseeable future.  Roughly 80% of the island land area is mapped Priority Habitat, as 
well as BioMap2 Core Habitat. Unlike other communities in the Commonwealth, Nantucket does 
not have designated Brownfields, highway roadsides, large parking lots suitable for solar 
canopies, industrial structures with adequately engineered roof areas, nor capped landfills that 
are encouraged and incentivized for development.  Restricting development in land mapped as 
Designated Priority Habitat is especially concerning for Nantucket, where nearly 50% of the 
island’s land area is already protected as open space--home to thriving populations of rare 
species (also attributable to the island’s remoteness). 

Based on recent discussions with the Land Use and Siting Solar Stakeholder Workgroup, we 
strongly oppose a “blanket restriction,” on designated priority habitat and instead support: 1) 
exceptions where the current permitting processes do not result in “a take,” and 2) the 
establishment of an exemption process for projects that are presumed to receive or are subject to 
“a take” determination. For example, there could be a clear, efficient, and expeditious system 
established for municipalities—and certain affected geographic areas (such as Nantucket), to 
request a waiver issuance by the Secretary of the EEA for projects where the benefits (economic, 
environmental, utility distribution) offset the impacts of development.

On the topic of Load Share Blocks, we are pleased to see that there is a separate block 
specifically allocated for the Nantucket Electric distribution zone, just as Nantucket Electric is 
allocated a separate net metering capacity from the rest of National Grid in the 
MassACA.  However, the proposed apportionment of 736kw per eight declining blocks is 
unreasonable and inappropriate for Nantucket.  For one reason, the allotment is significantly 
smaller than the largest project size allowed in the program (i.e. less than 5MW).  Furthermore, it 
is clearly apparent how the current block design is based on a high capacity, rapid solar 
development model, which is appropriate given the rate of solar growth elsewhere in the 
Commonwealth. However, on Nantucket where projects take significantly longer to permit, 
finance, and construct, this type of model simply does not work.

Given the increased cost of developing solar on Nantucket, it is our hope that an alternative 
block model be considered, perhaps allocating a larger minimum amount of capacity (i.e. 3MW) 
in blocks 1 and 2. The amount of block allotment must also closely match the current availability 
of Nantucket Electric’s net metering capacity (6.3MW). We are also interested to exploring 
whether Nantucket’s allotment can be absorbed into National Grid’s greater block allotment, 
only if an allocated, reserved amount—perhaps based on a percentage of Nantucket Electric’s 
historical peak load (48MW)— is specifically reserved for Nantucket projects.  A separate block 
amount is important because it will ensure that Nantucket can responsibly develop solar 
according to its own special considerations and timelines, and without competition from other 
National Grid territories. It will also help to ensure that adequate and valuable block capacity 
remains available by 2021, when Nantucket’s landfill is expected to be capped; becoming a 
prime location for solar development. 

Lastly, we ask that the DOER consider an additional tariff adder for “priority utility distribution 
zones” to help incentivize the development of solar systems in low saturation areas that are 
strategically installed and operated on certain electric distribution circuits, or are in targeted 
geographical locations with high electrical and Distributed Generation loads.   In the case of 
Nantucket’s energy forecast and need to reduce summer peak load, this incentive could help 
support an alternative system design, where panels could be oriented not to achieve maximum 
solar exposure and economic returns, but to achieve a closer match between peak system output 
and late afternoon peak-load demands.

Thank you for your consideration.

Sincerely,

Lauren M. Sinatra
Energy Coordinator
Town of Nantucket 
2 Fairgrounds Road
Nantucket, MA 02554

lsinatra@nantucket-ma.gov
office: (508) 325-5379
www.ACKEnergy.org 

