From:	Maynard S. Clark <maynard.clark@gmail.com>
Sent:	Wednesday, October 26, 2016 3:12 PM
To:	SREC, DOER (ENE)
Cc:	Maynard S. Clark
Subject:	Comments on state SRECII program

Surely you have heard comments as interesting, useful, and researched as these - and very likely 
far better than these.  
But the broad population-level implications of these and related decisions prompts me to speak 
out, even if and when others are doing far better in this topic.  Even if we are immediately 
disinterested in thinking about the complexities of solar energy policy, we're all impacted by 
decisions made about solar and wind in particular, and renewable energy in general.

When the current state SRECII program ends on January 8th, we will need an interim program 
before the new program begins.  We ought to be looking for a FAR HIGHER RPS for the 
Commonwealth, and we ought to be asking for RPS to rise faster than it is currently rising.

Now, incentive programs should include a fair definition of forested and agricultural land which 
does not discriminate against solar and wind development on agricultural, conservation, and 
other protected land AS OPPOSED to developments of any other kinds.  In other words, if ANY 
development is being considered for specially defined and protected lands, developments of solar 
and wind installations should not be unfairly treated.  Fair definitions should clealy NOT 
dismission or disadvantage solar and wind developers and developments from proceeding where 
other types of development are being considered.

Further, this newer incentive should involve and feature a higher adder fee structure and longer 
terms in order to encourgae projects to pencil in the final block, not merely the first block.

The proposal must include a system of assurance to lock in a block rate at the beginning of the 
project development cycle so that any project OWNERS can accurately predict their likely 
expenses for the projects.  What could be appropriate is a RESERVATION FEE similar to that 
of MassACA.

Annually reviewing block changes should help evaluate market signals, and perhaps more 
frequently.  Increasing block size and decreasing rte set in advance may be inadequate for our 
necessary and desirable solar build-out goals.

A number of Massachusetts cities have their own municipal light plants.  In order for municipal 
light plants to pay on a pro rata basis for their own subsidies, there could be an opt-in fund. 
 
Maynard
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Maynard S. Clark, MS (Management: Research Administration)
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