From:	Janice Kurkoski <jdauphin3@hotmail.com>
Sent:	Friday, October 28, 2016 4:57 PM
To:	SREC, DOER (ENE)
Subject:	comments on new solar program

Hello, 

I realize that this is last minute, but I think that your new program should consider the following:


1) It is crucial to create an interim program to fill the void between
 the January 8th expiration of the SREC II program and theimplementation of the new program.
 
2) The new incentive program should include a fair definition of
forested and agricultural land that does not discriminate against
solar development as opposed to any other type of development.
 
3) The new incentive should feature a higher adder fee structure and longer terms to encourage 
projects to pencil in the last block, not just the first block.
 
4) The proposal must include a system of assurance to lock in a block rate at the beginning of the 
project development cycle so project owners can accurately predict expenses. A reservation fee 
similar to MassACA may be approriate.
 
5) DOER should commit to revisiting block changes periodically (for example, once a year) to 
evaluate market signals. The increasing block size and decreasing rate set in advance may not be 
adequate to meet our solar build-out goals.
 
6) A solution for Municipal Light Plants would be to set up a fund that they can opt into, in order 
to pay for their own subsidies on a pro rata basis.

Thanks for your time,
Janice Kurkoski
Warwick MA
