From:	Kym Craven <kymcraven@aol.com>
Sent:	Friday, October 28, 2016 1:07 PM
To:	SREC, DOER (ENE)
Subject:	Next Generation Solar Incentive Straw Proposal - Comments

Good Afternoon, 
 
I appreciate the opportunity to provide feedback to you regarding the Next Generation 
Solar Incentive Straw Proposal as presented on September 23, 2016. 
 
Having spent the better part of the last year on a Solar Bylaw Committee I read with 
interest that DOER is proposed to eliminate the following from qualifying for the revised 
program:
 
•       Prime Farmland Soils
•       Prime Forest Land
•       BioMap2 Core Habitat and Critical Natural Landscape
•       Designated Priority Habitat of state-listed rare species 
 
While I did note that DOER may establish a process to consider exceptions on a case 
by case basis and create guidance on the types of exceptions that may qualify (e.g. 
inaccurate mapping). I believe that an absolute exclusion, and a case by case review for 
exceptions, can be severely limiting. 
 
In particular, in Townsend where I live, these restrictions would essentially make a 
ground mounted solar array impossible as nearly every inch of our town contains one or 
more of the above along with a significant amount of permanent open space. 
 
Any one of the above areas would be open to housing developing as long as the builder 
met certain conditions. While I want to protect all of the bullets above, there does need 
to be a balance. For example, a spot on your map might be listed as Prime Farmland 
but indeed not been farmed for over 20 years.  If the choices for the property are a solar 
array or housing, solar would be more beneficial for our community.  Additionally, many 
maps in Massachusetts show a location of having core habitat or rare specifies, but the 
exact location of the solar on a large track of land would not impact the habitat.  
 
I am hopeful that DOER will consider modified language when it comes to Prime 
Farmland, BioMap2 Core Habitat, and Critical Natural Landscape or Designated Priority 
Habitat of state-listed rare species that it would be allowed as long as impact is not on 
the exact location and steps to mitigate harm would be in place as would be the cases if 
buildings were to be erected in these locations. 
 
Thank you for your consideration. 
 
Kym Craven
978-314-7283
87 Lunenburg Road
West Townsend, MA 01474
