Solar in the Ag Reserve – The Poolesville Green Perspective

Solar in the Ag Reserve – The Poolesville Green Perspective

Poolesville Green is detailing here our reasons for supporting Community Solar in the Agricultural Reserve through Zoning Text Amendment (ZTA) 20-01. 1 As a result, we ask you to support it as well. Where appropriate, we placed endnotes as references to support our position.

Links to specific issues on this page:

Issue Overview

County Council will take up the ZTA 20-01 soon. These projects would be limited to <2 megawatts (approx. 10-12 acres) each and be restricted, in total, to no more than 2% (1800 acres) of the 93,000 acre Ag Reserve.2 Only one project would be allowed on each farm, no matter how large the farm.3

Our county declared a climate emergency with the goal of an 80% reduction in greenhouse gas emissions by 2027 and 100% reduction by 2035.4 We see the ZTA as a key to meeting those goals as it “could reduce overall County carbon emissions by up to 4.4%”.5

Net Metering and its Community Solar and Aggregated Net Energy Metering Programs

The ZTA points to the state statutes that define community solar.6 In our view, this makes sense and is better than putting the term ‘community solar’ in the ZTA.  The state’s Community Solar program and Aggregate Net Energy Metering (ANEM) program fall under the state’s net metering statutes. ANEM program is only allowed for three entities: non-profits, agriculture and local/state government, a small customer base as compared to the residential customer base for community solar. To exclude agriculture’s access to an ANEM project in the AR makes no sense and therefore we have no objection to how the ZTA references state statutes about net metering that include both the Community Solar and ANEM programs. As written, the ZTA provides for Community Solar projects, which allow renters and others who can’t install rooftop solar to subscribe and receive discounted rates.

By law and according to the state’s community solar program, 30% of the capacity of projects must be for low and moderate income (LMI) consumers. The LMI component is usually a mixture but there are some projects that are targeting 100% LMI participation. State regulations require that 30% of the total capacity allocated in a utility service area be allocated to projects with an LMI component. There is also an opportunity for developers to build projects in the small-brown-field other (SBO) category if they have at least 50% of their subscribers be LMI-qualified. This is a carrot for developers to try to get access to the program in either category. Finding land has been a challenge for the projects in Pepco service area and LMI projects in particular so the Pepco part of the AR will be a good source of those projects.

The ZTA, as amended, contains strong protections for forests, high-quality soils, steep slopes, wetlands, and other environmental concerns while also being subject to existing protections from other regulations.

Solar at Dickerson?

Why not just put solar at the decommissioned Dickerson coal plant? This is a great idea and fully support moving this idea forward, but it will only add a small part of the 2,500 MW of solar needed by our county to reach 100% clean energy and only one-fifth as much as the ZTA. In our climate reality, we need both.

The Opportunity of Agrivoltaics

The ZTA, as amended, requires that projects include one of three agriculturally friendly Agrivoltaic practices: 1) Pollinator Friendly Designation as defined by the State; 2) “planted, managed, and maintained in a manner suitable for grazing farm animals”; or 3) “planted, managed, and maintained for any other agrivoltaic plant material”.7 We expect and support a change to further strengthen this part of the ZTA. Not only can pollinator-friendly solar support nearby crops (studies show their yield increases), but the economic benefits to farmers help them stay in farming. We’ve added a host of references, studies, articles about Agrivoltaics in the endnotes.8

This Now This video “Agrivoltaics: Solar Panels Bring Life to Struggling Farms” outlines why we feel so strongly about it and in particular provides a first-hand account from a small farmer on an urban area edge who fought for a change in zoning to allow just the kinds of agrivoltaic farming practices we support for this ZTA. This is 21st century farming for the 21st century farmer.

Table Crops in the Ag Reserve

The Ag Reserve is a vital part of our county yet only 1.3% of the total farmland is used for table crops: those consumed locally like vegetables, orchard fruits, berries, and others. It provides less than 1% of the county’s food.

Electricity Distribution and Transmission Lines

Since the late 90’s the electric system in the mid-Atlantic region has been deregulated, which means that regulated utilities cannot own or operate generation facilities – those facilities operate as deregulated businesses – outside the jurisdiction of state public service commissions.  You may remember that during this time, Pepco sold all its generating plants as a result of this regulatory change. 

In the mid-Atlantic region, the bulk power system, which we typically call the transmission system, and the generating stations are all coordinated by PJM, and the owners and operators of those facilities must abide by PJM processes.

Today, if a company wants to install a large generator, they must abide by PJM rules and that includes a comprehensive review of the transmission system capacity to ensure that there is sufficient capacity.  However, for small generation projects (less than 10 MWs) PJM review is not required. 

In the old days of vertically integrated utilities the construction of all generation and transmission and distribution was aligned and closely coordinated.  That is no longer the case. 

With distributed generation being placed on rooftops and small fields, there has been a change in the way the planning process works.  Customers choosing to put solar on their roof may ultimately mean that utilities must upgrade their distribution lines for stability, or to allow additional growth of rooftop solar.  That does in fact mean that customers will pay more – the upgrades are not free.  However, most of us think this is a reasonable process to increase renewable energy on the electric system.

The community solar arrays in Maryland are generally limited to 2 MW capacity (there is an exception for brownfield construction which is definitely not under consideration in the Ag Reserve). These solar arrays will connect to the electric system via distribution lines and are therefore under the jurisdiction of the Maryland Public Service Commission, not the Federal Energy Regulatory Commission (FERC).

Some have expressed concern that siting solar generation in the Ag Reserve will cause the capacity problems on the transmission system.  While we do not know if this is true or not, our position is that this does not matter.  Customers choose to put generation on their rooftops without consideration of the impact on the electric system because our regulators decided to allow that to happen and our legislators decided to incentivize people to do that, to help meet our state and local renewable energy goals. We would further argue that this is completely consistent with the federal decision to deregulate generation in the first place – that removing regulations on generation would create a more efficient generation marketplace and spark innovation.  

We recognize that this subject gets arcane quickly and can provide more information if needed. 

Community Solar = Climate Justice

Community solar will allow Montgomery County citizens in multi-family housing and/or those of low and moderate income the ability to purchase low cost clean electricity and support local clean energy jobs. This is what climate justice looks like.

We see allowing solar in the Ag Reserve, in particular Community Solar projects, as a question of whether all communities in the County will do their part to save our people and environment from the dangers of climate change.

Our warming climate will not wait for us to study, invent, and test for perfect solutions. We need to act now.

Express your support to the County Council at:

  • 20201006_11A Full Council Worksession ZTA 20-01 amended draft
  • Agrivoltaic References & Resources as of Sept 2020
  • Argonne Nat Labs Study_Ag Benefits from Pollinator Friendly Solar May 2018
  • est.8b00020.pdf
  • Blog_Sierra Club_Why we support the solar Zoning Text Amendment (ZTA) in Montgomery
  • County_Sierra Club 200820.pdf
  • Boucher – The Rental of Farmland in Montgomery County in relation to ZTA 20-01.pdf
  • Boucher_3March2020_Testimony-ZTA20-01,MontgomeryCountyCouncil.pdf
  • Boucher_12March2020-Additional testimony to the County Council in favor of ZTA 20-01.pdf
  • Copy of Solar-reforestation-regenerative ag – per-acre reduction of CO2 emissions, Montgomery
  • Cty, MD.pdf
  • Gagnon_2016_NRELTechRept-RooftopSolarPotentialUSDetailedAssessment.pdf
  • Great_Clash_Merrill June 2020.pdf
  • MoCo AgRes &amp; PepcoPE boundary.pdf
  • Monocle Ad Full Page Solar in AgReserve Final 201005.pdf
  • Monocle Ad_Pvl Grn_Solar in AgReserve FINAL 200904.pdf
  • Opinion_communit Solar on Farmland Is an Issue of Climate Justice_Maryland
  • Matters_Boucher_Hansley 201002.pdf
  • Poolesville Green – Recommendations to the Count Council on ZTA 20-01 200629.pdf
  • Siegner_2019_YaleCtrBusinessEnvRept-Graphic-BenefitsFromSolarVsCropsAlone-Soy+Corn.pdf
  • Solar Ag Reserve Electric system KLefkowitz 200816.pdf
  • USDA-NASS-2019_2017AgCensus-Maryland-CountyLevelData-WithHighlighting.pdf
  • ZTA 20-01 Breiner Full Written Public Testimony Final 200302 public distribution.pdf

1 Ag Reserve Solar ZTA – Fact Sheet
2 ZTA 20-01 CLEAN (not legisalative format) with joint committee amendments from july 16 
3 State Statute 
Montgomery County County Council Resolution# 18-974  
5 Ag Reserve Solar ZTA – Fact Sheet
6 3.7.2.A as seen in ZTA 20-01 CLEAN (not legisalative format) with joint committee amendments from july 16
7 ZTA 20-01 CLEAN (not legisalative format) with joint committee amendments from july 16
8 AGROVOLTAIC REFERENCES AND RESOURCES: Short Overview Video from Now This news outlet, Sept 2020: Agrivoltaics: Solar Panels Bring Life to Struggling