Industry organizations and advocates representing Massachusetts’ 488 solar employers are joining forces in calling for significant changes to be made to the state Department of Energy Resources’ (DOER) Solar Massachusetts Renewable Target (SMART) Program.

As previously reported, SMART is a long-term replacement program designed to incentivize 1.6 GW of new solar generating capacity through a “declining block” structure, with base compensation rates reducing by set percentages in each block.

The eight trade and advocacy associations – embracing all sectors of this industry of nearly 15,000 employees – have filed formal written comments to the Baker administration, urging reforms to the proposed program to ensure the state can continue a long history of clean energy leadership and innovation.

“While the SMART program has the right aim — to double the state’s solar capacity and bring solar to more people in Massachusetts — it needs the critical improvements listed here to ensure its goals are met,” says David Gahl, director of state affairs for the Northeast at the Solar Energy Industries Association. “The SMART program is meant to be a long-term policy that provides certainty for solar companies in the state, which is why it’s so important this be done right. With these revisions and an update to the state’s net-metering policy in the fall, Massachusetts will grow its economy, protect solar jobs and maintain its position as one of our country’s leading solar states.”

“Every ratepayer in the commonwealth deserves the opportunity to receive the benefits of solar energy on their electric bill through participation in community solar,” says Coalition for Community Solar Access Executive Director Jeff Cramer. “Without our recommended changes, the SMART program will curtail community solar and greatly restrict access to clean energy. We are united in our commitment to working with the state to improve the SMART program and enable on-bill crediting to ensure it works for everyone.”

“The regulations put forth by the Department of Energy Resources offer the potential for a promising framework for continued solar development,” says Peter Rothstein, president of the Northeast Clean Energy Council. “However, the solar industry has identified several essential modifications necessary to ensure that the program will support sustainable solar growth and achieve the Baker-Polito administration’s 1,600 MW solar goal for the commonwealth. We commend DOER for the extensive work and stakeholder engagement conducted to arrive at the new program. With the improvements the industry has identified, we are confident that SMART will allow Massachusetts to maintain its solar leadership and continue capturing energy, economic and environmental benefits for its residents, businesses and cities.”

The groups raised concerns about the five following key parts of the SMART solar proposal:

1. The proposed compensation rates are not sufficiently robust to encourage continued solar development and protect solar jobs in the commonwealth.

2. Caps on certain incentives (called “adders”) will slow growth in community solar, low-income solar and solar + energy storage projects around the state.

3. Net-metering caps should be raised, and the on-bill crediting mechanism must be developed urgently.

4. DOER should clarify and improve new land use and siting criteria, performance standards, special provisions, and greenfield subtractors to provide the market and landowners with more certainty.

5. Small-scale residential and low-income solar projects should be compensated fairly.

“Massachusetts has built a strong foundation of solar policies that have helped create a cleaner energy system, healthier communities, and thousands of good, local jobs. Governor Baker has the opportunity to build on that base, but he will need a SMART-er solution,” says Sean Garren, Northeast director of Vote Solar. “We have laid out a path to a better SMART program, and we hope that Governor Baker and DOER will lead us to a sunnier, solar-powered commonwealth.”

“Together, we must ensure there is a resilient and reliable market for solar energy in the near and long term. Solar has become a mainstream technology that Massachusetts residents, businesses and institutions can own and operate – a technology that produces local clean energy, saves money, and lightens the electric burden on the utility grid while reducing the use of fossil fuels,” says William Stillinger, president of SEBANE. “The several improvements we are recommending to the SMART program regulations are critical to energizing the Massachusetts economy, maintaining and growing jobs here, and keeping our environment clean and safe for our communities and for future generations.”

“The SMART program aims to support a broad diversity of solar projects, including rooftop and solar canopy projects, residential, low-income, community-shared solar, and public projects. However, it is extremely difficult to set appropriate levels of compensation to achieve those goals 12 to 18 months before the start of a four-year program,” says Mark Sandeen, president and co-founder of MassSolar. “We recommend that the administration review program performance early and often and build in a mechanism to adjust compensation levels if necessary to achieve the SMART program’s project diversity goals in light of changing market conditions.”