The July 6, 2023, report presented by Synapse Energy Economics, Inc. concludes that “Massachusetts’ technical solar potential is 506 GWAC, 15 to 18 times greater than the amount required by the [Massachusetts Clean Energy and Climate Plan for 2025 and 2030 (CECP) and the Massachusetts Clean Energy and Climate Plan for 2050 (2050 CECP)] (27 to 34 GW).” For solar developers and cities and towns contemplating ground-mounted solar facilities, three cases, Commonwealth of Massachusetts v. Dynamic Energy Solutions, LLC, 2020 WL 8837781 (D.Mass.), ASD Three Rivers MA Solar, LLC vs. Planning Bd. of Wilbraham, Mass. Land Ct., No. 19 MISC 000089 (DRR) (Apr. 5, 2021) and PLH, LLC v. Ware, 102 Mass. App. Ct. 1103 (2022) (Unpublished Disposition) illustrate that municipalities must create and adhere to sound permitting bylaws and ordinances to balance legitimate municipal interests (particularly with respect to erosion control, grading and drainage) with the Commonwealth’s ground-mounted solar development goals.