From: Sarah Demb <sarah.demb@gmail.com>
Sent: Monday, June 10, 2019 5:31 PM
To: RPS, DOER (ENE)
Subject: SREC I eligibility rules and proposed regulatory change
Dear
Mr. Wassam,
I write to express my
strong concern about the DOER proposal to limit the SREC I eligibility for
existing solar projects, which represent a substantive modification of the SREC
I program rules.
The SREC I regulations
currently allow solar projects to generate SRECs for the entirety of the SREC I
program. DOER seeks to shorten this SREC eligibility period and only permit
solar projects to generate SRECs for the first 40 quarters in which they are
eligible.
A plain reading of 225
C.M.R. 14.00 unambiguously demonstrates that solar projects retain their SREC I
eligibility through the end of the program (See 225 C.M.R. 14.07. )
Truncating SREC I eligibility would be detrimental to the many homeowners,
businesses, municipalities, and others who helped launch the Commonwealth’s
solar industry. Changing the rules mid-program would not only violate the
legitimate expectations of SREC I solar project owners, it would undermine
trust in the Massachusetts solar market and potentially impact the ability to
develop and finance new solar projects in what is an already challenging
environment.
I strongly urge DOER
not to adopt the proposed changes and ensure SREC I solar projects retain their
eligibility through the end of the program as intended.
Thank you for your
consideration.
Sarah DembWATERTOWN,
MA 02472