From:                                                       John Leonard <toomuchfun33@gmail.com>

Sent:                                                         Tuesday, June 4, 2019 4:51 PM

To:                                                            RPS, DOER (ENE)

Subject:                                                   Proposed Retroactive Change to SREC 1 Program

Attachments:                                         solarLeonardSpreadSheet.xlsx

 

                                                                                                                                             600 Main St.

                                                                                                                                             Hingham, MA  02043

                                                                                                                                             June 4, 2019

John Wassam

Massachusetts Department of Energy Resources 

RE: Proposed regulatory changes to SREC I eligibility, 225 C.M.R. 14.00

 

Dear John Wassam,

    Hello and good day!  I'm a residential solar owner and I am upset to learn about a proposed Department of Energy Regulation change in policy.  The change I am concerned about would cut back participation in the state SREC 1 program from 2023 back to 2021.   

    Speaking for our family's moderate-sized 3.68kW solar array on top of our house, we paid $7.74/Installed Watt back in the Summer of 2011.  Being an early adopter of solar, we paid a very high price for our installation.  Today, the common price per installed Watt is $3.80 or less.  And the panels are often of a higher efficiency now than what ours are.  We paid over double the current average price back in 2011.  When we include all the costs, it will be well beyond 10 years before we come anywhere close to breaking even.  Including the expected costs of replacement of our central inverter in the near future, it will take about 9 1/2 years to recoup what we paid, including in all the rebates.  What that 9 1/2 years does not include is the opportunity costs from removing the money from the stock market to pay for the solar panels.  Figuring in those costs, it will be several years more till we truly break even.  I am including a spread sheet where I have carefully documented all expenditures and income since the solar panels coming on line at the end of 2011. Cutting off our SREC payments in 2021 rather than the originally stated end in 2023 will make it that much further away from breaking even.  I estimate this possible regulation change to personally cost us something on the order of $3,000.  It is not a good thing for us to make an expensive investment in the house, base the math, in part, on a promise from the state and then, retroactively, have the rug pulled out from under us.  It is irresponsible for the state to make a promise, for us to financially extend ourselves and then have the state renege.  What does that say to a home owner that wants to do something about global warming?  We certainly weren't doing this to become rich.  And has bad as it is for a residence, this is even worse for a commercial developer as it so much more potential money to lose.  It is wrong to do this for those taking a large financial risk, who are at the same time helping to solve a major problem.  And as wrong as it is to do such a thing in the present time, this robs credibility from the state giving it's word.  Commercial developers are not going to take the state at their word in the future.  What looks like a future money earner to a developer may become a money loser if the state does the same thing again at some future time.  This is going to act to scare away to some degree future solar development.

      I ask you to please reconsider this regulatory change.

                                                                                                                              Sincerely,

                                                                                                                              John Leonard