ELM Assists with SMART 3.0 Updates Advancing Responsible Solar Development in Massachusetts

August 1, 2025 – Input from the Environmental League of Massachusetts (ELM) is helping Massachusetts site, build, and deploy responsibly developed solar. ELM submitted comments to the Department of Energy Resources (DOER) in response to the SMART 3.0 emergency regulations filed on June 20. These revisions represent a critical step toward advancing solar policy in alignment with the Commonwealth’s climate and biodiversity goals, while ensuring responsible siting and long-term affordability.  

ELM commends DOER for evolving the SMART Program to reflect the maturity of Massachusetts’ solar industry and the urgency of achieving its 2030 and 2050 Clean Energy and Climate Plan targets. The revised framework recognizes that how and where we build solar matters, and that well-designed incentives are key to balancing emissions reductions with equity and affordability.  

“As solar deployment accelerates, our Commonwealth must lead with an eye to climate ambition, land protection, and price flexibility,” said Erin Smith, Clean Grid Director at the Environmental League of Massachusetts. “DOER’s updates to the SMART Program represent an effective recalibration – one that builds confidence in clean energy investments while preserving Massachusetts’ natural assets.” 

ELM’s comments emphasize several core priorities:  

• Supporting incentives for solar projects that keep up with changing market conditions while protecting land and benefiting surrounding communities.  

• Prioritizing incentives for solar on canopies and shared community solar projects that minimize land conversion and deliver public benefits; 

• Protecting forests, wetlands, and communities by including carbon storage, ecological integrity, and cumulative impacts in siting decisions; and 

• Including a mitigation fee and environmental monitoring system to guide responsible development on sensitive lands.  

As Massachusetts scales its clean energy economy, ELM works to prioritize responsible deployment that protects biodiversity, lowers costs, and creates healthier communities. 

ELM thanks Commissioner Elizabeth Mahoney and the Healey-Driscoll Administration for their thoughtful stewardship of the SMART 3.0 Program and their ongoing commitment to a clean, just, and sustainable energy future. We look forward to continued collaboration on this vital work.