High Level
Massachusetts closed out a multi‑year, data‑driven review by
issuing final SMART 3.0 regulations that recalibrate incentives, refine siting
and storage rules, and annualize key parameters to speed distributed solar and
better protect ratepayers. At the same time, USDA moved to severely restrict REAP
support for ground‑mounted solar on productive farmland and to bar panels from
“foreign adversaries,” an action aligned with this year’s One Big Beautiful
Bill Act’s accelerated repeal of many clean‑energy credits. The week captures a
widening divergence: states like Massachusetts are tightening programs with
evidence and stakeholder process, while federal actions are narrowing farmer
and rural‑business energy choices and adding policy risk to community‑scale
solar.
Full View
Massachusetts finalizes SMART 3.0 to reboot community and
commercial solar with annual, data‑driven settings
• What happened: The Massachusetts Department of Energy Resources filed final
SMART 3.0 regulations on August 28, 2025, following emergency rules in June
and a public comment process. The Final Regulations and the Program Year 2025
Annual Report establish annual capacity blocks, compensation parameters, and
other attributes to keep incentives aligned with market conditions.
• Who did it: Massachusetts DOER, under the Healey‑Driscoll
Administration.
• Why they did it: DOER’s programmatic review found the prior structure
needed updates to keep projects financeable, improve siting and storage
integration, and enhance low‑income access, while protecting ratepayers. The
3.0 framework formalizes annual adjustments and clarifies siting and
mitigation provisions.
• Stakeholder views:
• “SMART 3.0 charts a strong path for community and commercial
scale solar and storage in Massachusetts and will be critical for driving down
energy costs for families.” — Valessa Souter‑Kline, SEIA.
• “Going big on solar now is the best way to unlock affordable,
local, clean energy generation for the Commonwealth.” — Kate Daniel, CCSA.
• ACT praised the rules as timely and targeted amid a difficult
federal climate.
• Environmental League of Massachusetts supported stronger rooftop
and low‑impact siting signals and suggested restoring a rooftop raised‑racking
adder to further steer deployment off greenfields.
• What happens next: Final SMART 3.0 becomes effective upon publication
in the Massachusetts Register on Sept. 12, 2025; DOER will administer
2025 program‑year blocks under the Annual Report. Developers should track DOER
guidance and any utility tariff updates that implement the new parameters.
Sources:
Mass.gov (DOER), “SMART 3.0 Program Details,” Aug. 28, 2025 — https://www.mass.gov/info-details/smart-30-program-details
Mass.gov (DOER), “SMART Program Year 2025 Annual Report,” 2025 — https://www.mass.gov/doc/smart-program-year-2025-annual-report/download
SEIA, “Solar Industry Applauds Release of Final SMART 3.0 Regulations,” Aug.
29, 2025 — https://seia.org/news/solar-industry-applauds-release-of-final-smart-3-0-regulations-by-massachusetts-department-of-energy-resources/
Foley Hoag, “SMART 3.0 Program Key Changes and Features,” July 25, 2025 — https://foleyhoag.com/news-and-insights/blogs/energy-and-climate-counsel/2025/july/smart-3-0-program-key-changes-and-features-mitigation-fees/
MassInsider (SEBANE statement), “New Solar Programs …,” June 2025 — https://massinsider.net/press-releases/41857
USDA restricts REAP support for on‑farm solar and bars
“foreign adversary” panels, citing protection of prime farmland
• What happened: USDA announced it will no longer fund wind and
solar on productive farmland, will bar USDA‑funded projects that
use panels from “foreign adversaries,” and will tighten REAP eligibility
by excluding ground‑mounted systems over 50 kW or projects that cannot
document historical on‑site usage. It also removed priority points for REAP
grants and made wind and solar ineligible for the Business & Industry
Guaranteed Loan Program.
• Who did it: U.S. Department of Agriculture; Secretary Brooke Rollins.
• Why they did it: USDA states the changes protect prime farmland and
national security. Secretary Rollins: “We are no longer allowing businesses to
use your taxpayer dollars to fund solar projects on prime American farmland,
and we will no longer allow solar panels manufactured by foreign adversaries to
be used in our USDA‑funded projects.”
Context: These moves track the One Big Beautiful Bill Act,
which accelerates the end of multiple clean‑energy credits (including the Residential
Clean Energy Credit) and adds FEOC restrictions, and complement recent
import‑content rules.
• Stakeholder views:
• “USDA’s new anti‑renewable energy policies restrict farmers’
choices over their own land… These limits hinder farmers’ ability to generate
energy independently [and] create new revenue streams.” — Andy Olsen,
Environmental Law & Policy Center. (
• “Farmers don’t want Washington telling them what they can and
can’t do with their land… Where USDA REAP is being scaled back, community solar
is stepping up.” — Jeff Cramer, CEO, CCSA.
• Reuters notes USDA stopped short of ending all support,
but is moving away from larger facilities; USDA data show only a very small
share of rural land is used for wind and solar and much continues in
agricultural use.
• What happens next: USDA’s restrictions are in effect. Farmers and
rural businesses will have fewer federal pathways for on‑farm solar; developers
will pivot to smaller, behind‑the‑meter designs and to state‑enabled community
solar leases to replace lost REAP economics. Trade groups are marshaling
opposition and may seek Congressional oversight and litigation
Sources:
USDA, “Secretary Rollins Blocks Taxpayer Dollars for Solar Panels on Prime
Farmland,” Aug. 19, 2025 — https://www.usda.gov/about-usda/news/press-releases/2025/08/19/secretary-rollins-blocks-taxpayer-dollars-solar-panels-prime-farmland
Reuters, “USDA will heighten scrutiny for solar and wind projects on farms, but
some may continue,” Aug. 19, 2025 — https://www.reuters.com/sustainability/boards-policy-regulation/usda-will-heighten-scrutiny-solar-wind-projects-farms-some-may-continue-2025-08-19/
pv magazine USA, “USDA announces it will discontinue funding solar projects,”
Aug. 19, 2025 — https://pv-magazine-usa.com/2025/08/19/usda-announces-it-will-discontinue-funding-solar-projects/
Solar Power World, “USDA adds restrictions for REAP-funded solar projects,”
Aug. 19, 2025 — https://www.solarpowerworldonline.com/2025/08/usda-adds-restrictions-for-reap-funded-solar-projects/
Coalition for Community Solar Access, “As USDA Scales Back REAP Funding,
Community Solar Steps Up…,” Aug. 21, 2025 — https://communitysolaraccess.org/news/as-usda-scales-back-reap-funding-community-solar-steps-up-to-support-family-farms-and-rural-economies
ELPC, “USDA Rollback on Solar Strips Rural America of Land and Energy Choices,”
Aug. 19, 2025 — https://elpc.org/news/usda-rollback-on-solar-strips-rural-america-of-land-and-energy-choices/
Solar Builder, “Trump’s USDA shuts down REAP funding for solar to aid farmers,”
Aug. 26, 2025 — https://solarbuildermag.com/policy/trump-usda-shuts-down-reap-funding-for-solar-to-aid-farmers/
IRS, “One, Big, Beautiful Bill Act of 2025 provisions,” Aug. 22, 2025 — https://www.irs.gov/newsroom/one-big-beautiful-bill-act-of-2025-provisions
What’s the So What?
Massachusetts is leaning into a facts‑and‑process
model. SMART 3.0 arrives after a programmatic review, public hearings, and an
Annual Report mechanism that sets capacity, rates, and adders every year. The
structure reflects how community solar succeeds in practice: predictable
blocks, transparent rules, and siting signals that steer toward rooftops,
parking canopies, and lower‑impact land while preserving ratepayer value. The
state is using iterative rulemaking to keep dollars flowing even as federal
incentives are compressed under OBBB. (Foley Hoag, Mass.gov)
By contrast, USDA’s action narrows rural energy choices and
undercuts farm resilience. The agency says it is “protecting prime farmland,”
but its blanket approach ignores empirical siting solutions already used in
agrivoltaics and the small footprint renewables actually occupy in rural
America. It also strips away a voluntary, bipartisan tool that has reduced
operating costs for farmers and rural businesses since 2002. In Avenra’s view, Rollins
is wrong: curtailing REAP for on‑farm solar is bad for energy
affordability, bad for resilience, and bad for national security because it
reduces distributed generation that keeps lights on when the bulk system fails.
Community solar can fill some of the gap, but it is not a substitute for on‑farm
self‑generation supported by a stable federal partner. (Reuters,
Environmental
Law & Policy Center, Coalition
for Community Solar Access)
Policy through the lens of OBBB amplifies the harm. The law
accelerates the sunset of the Residential Clean Energy Credit and
imposes broad FEOC restrictions, injecting deadline and supply‑chain risk into
small‑scale solar. USDA’s REAP limits layer on top of those headwinds, further
weakening the business case for rural solar exactly when new load and weather
volatility argue for more distributed, local supply. The Commonwealth’s SMART
3.0 is, in effect, a counter‑cyclical hedge against federal
retrenchment. Expect states with community solar legislation to follow
Massachusetts’ lead by tightening program design and siting criteria while
expanding capacity and low‑income access to sustain momentum through the
federal policy whiplash. (IRS)
Bibliography
Massachusetts Department of Energy Resources. “SMART 3.0
Program Details.” Aug. 28, 2025. https://www.mass.gov/info-details/smart-30-program-details
Massachusetts Department of Energy Resources. “SMART Program Year 2025 Annual
Report.” 2025. https://www.mass.gov/doc/smart-program-year-2025-annual-report/download
Solar Energy Industries Association. “Solar Industry Applauds Release of Final
SMART 3.0 Regulations by Massachusetts DOER.” Aug. 29, 2025. https://seia.org/news/solar-industry-applauds-release-of-final-smart-3-0-regulations-by-massachusetts-department-of-energy-resources/
Foley Hoag LLP. “SMART 3.0 Program Key Changes and Features.” July 25, 2025. https://foleyhoag.com/news-and-insights/blogs/energy-and-climate-counsel/2025/july/smart-3-0-program-key-changes-and-features-mitigation-fees/
Environmental League of Massachusetts. “SMART 3.0 Emergency Regulations Public
Comment.” July 25, 2025. https://www.environmentalleague.org/wp-content/uploads/2025/08/SMART_3.0_ELM_Comments.pdf
U.S. Department of Agriculture. “Secretary Rollins Blocks
Taxpayer Dollars for Solar Panels on Prime Farmland.” Aug. 19, 2025. https://www.usda.gov/about-usda/news/press-releases/2025/08/19/secretary-rollins-blocks-taxpayer-dollars-solar-panels-prime-farmland
Reuters. “USDA will heighten scrutiny for solar and wind projects on farms, but
some may continue.” Aug. 19, 2025. https://www.reuters.com/sustainability/boards-policy-regulation/usda-will-heighten-scrutiny-solar-wind-projects-farms-some-may-continue-2025-08-19/
pv magazine USA. “USDA announces it will discontinue funding solar projects.”
Aug. 19, 2025. https://pv-magazine-usa.com/2025/08/19/usda-announces-it-will-discontinue-funding-solar-projects/
Solar Power World. “USDA adds restrictions for REAP-funded solar projects.”
Aug. 19, 2025. https://www.solarpowerworldonline.com/2025/08/usda-adds-restrictions-for-reap-funded-solar-projects/
Coalition for Community Solar Access. “As USDA Scales Back REAP Funding,
Community Solar Steps Up to Support Family Farms and Rural Economies.” Aug. 21,
2025. https://communitysolaraccess.org/news/as-usda-scales-back-reap-funding-community-solar-steps-up-to-support-family-farms-and-rural-economies
Environmental Law & Policy Center. “USDA Rollback on Solar Strips Rural
America of Land and Energy Choices.” Aug. 19, 2025. https://elpc.org/news/usda-rollback-on-solar-strips-rural-america-of-land-and-energy-choices/
U.S. Internal Revenue Service. “One, Big, Beautiful Bill Act of 2025
provisions.” Aug. 22, 2025. https://www.irs.gov/newsroom/one-big-beautiful-bill-act-of-2025-provisions
U.S. House Ways & Means Committee. “The One Big Beautiful Bill: Section‑by‑Section.”
May 12, 2025. https://waysandmeans.house.gov/wp-content/uploads/2025/05/The-One-Big-Beautiful-Bill-Section-by-Section.pdf