From:	Scott Howe <showe@solectinc.com>
Sent:	Friday, October 28, 2016 4:58 PM
To:	SREC, DOER (ENE); SREC, DOER (ENE)
Cc:	Ken Driscoll; James Dumas; Craig Huntley
Subject:	Comments to the Strawman Proposal

Michael Judge, Director
Renewable and Alternative Energy Division
Massachusetts Department of Energy Resources

Dear Michael,

On September 23rd DOER presented a Strawman proposal briefing on the next phase of the Solar Carve 
Out and asked the industry for comments. Solect Energy appreciates the efforts by DOER to obtain 
feedback from the industry with the intent of “Maintaining robust growth across installation sectors”.

Solect Energy has participated in the Massachusetts Solar Industry for the past seven years and has 
grown to 56 full time employees, and over 200 contracted employees. This year we will install over 25 
MWs of new Commercial solar projects with the average project size of 280 KW. In total we have 
installed over 300 Commercial solar PV systems, nearly 60 MWs, with over 95% being on rooftops.
We support the Solar Coalition’s response that included SEBANE, NECEC, MassSolar, SEIA, Vote Solar, 
and others that called out the following top concerns:

*	Solar market continuity during the transition – Any gap between SREC II incentives and the next 
set of solar incentives creates significant market uncertainty, especially from the lending 
community, and has the potential to cause workforce reductions.
*	Designing the incentive program to last for more than a few years – Eliminating market 
uncertainty which support the Commonwealth’s Carbon Reduction Goals and allows companies 
like Solect to have a clear path to invest in our companies and the local market..
*	The level of tariff rates and implementing the blocks – Our primary concern are getting the 
tariff rates fair so CapEx investment will flow toward energy investment and eliminating 
uncertainty in the tariff rate you will receive in a declining block structure.
*	Restrictions on land use and siting – The DOER should not unfairly impose siting restrictions 
that do not apply to other development projects.
In addition, we would like to provide the following comments supporting these positions: 

*	Tariff rate design
o	We would ask you to consider different terms for behind the meter applications versus 
standalone solar meters. For behind the meter application consider offering a 10 year 
tariff term which helps for faster payback when companies are considering investing 
CapEx . For standalone meters offer 20 year terms due to the uncertainty of the future 
of net metering, and whether class-1 RECs will be available after the FIT incentive ends.
o	Solect has modelled thousands of commercial systems and would be willing to 
participate in any DOER workshops to share data. We feel strongly the tariff should 
reflect an ROI that encourages continued investment in Commercial Solar projects. We 
do not feel you need two Commercial categories, just the appropriate tariff rate for the 
appropriate project size. We completed modelling that would support the following 
tariff for Commercial roof tops (base plus building rooftop adder):
 
o	Another consideration would be to have an adder for utility interconnect study results 
requiring infrastructure upgrades that exceed $.10 per Ac watt. We are now seeing a 
significant amount of added costs coming from the utilities to upgrade feeder lines and 
substations that benefit the overall grid. These costs should not be solely born by one 
project. 
*	New Adders: We agree with the solar coalition’s survey results that “non for profit” business 
will be disadvantaged in this tariff structure and there should be a new adder considered. 
There are many positive aspects of the new program, and we realize there are still many specifics that 
need to be worked out. We applaud DOER’s efforts and willingness to work with the industry to 
establish a program that is fair and workable to both ratepayers, utilities and the solar industry. Solect is 
available for any questions and would be available to participate in any future workshop.

Best regards,

Scott Howe | Partner | SVP

 

Solect Energy Development
89 Hayden Rowe St. | Hopkinton, MA 01748
solect.com | showe@solect.com

Connect with us on LinkedIn | Twitter | Facebook 

****The information contained in this e-mail, and any and all accompanying documents, constitutes confidential information.  If you 
are not the intended recipient of this information, any disclosure, copying, distribution, or the taking of any action in reliance on it is 
strictly prohibited.  If you have received this information in error, please notify the sender immediately and destroy this 
communication.  Messages sent via this medium may be subject to delays and/or unauthorized alteration.  Neither Solect Energy 
Development, LLC. nor any of its affiliates or subsidiaries shall be held liable for the contents of this message. ****

