From:	David Pantalone <david.pantalone@verizon.net>
Sent:	Thursday, October 27, 2016 3:14 PM
To:	SREC, DOER (ENE)
Subject:	Comments on DOER Proposed Solar Incentives

1.	The Proposal for Solar Incentives released by DOER in early October has been 
reviewed by MassSolar and discussed publicly. Their review, which is published 
on SolarIsWorking.org, acknowledges the value in many of the goals of the 
proposed policy. However this particular proposal is sufficiently lacking in many 
regards. 

The dangers presented by climate change and the goals set forth by the Global 
Warming Solutions Project are urgent. The latter will not be met unless aggressive 
incentives that safeguard the health and development of the solar industry in the 
near term and long term are adopted quickly. 

The basic comments that MassSolar has provided on the DOER proposal are 
listed at the bottom of this email and I fully support those comments.

In addition, I would like to draw attention to the fact that at Spring Town 
Meeting in Brookline this year, Warrant Article 20 was passed that was also 
aimed at showing support for policy development at the state level that is fully 
supportive of the solar industry and that addresses some of the short comings of 
current net metering policy. This Warrant Article passed by an almost 
unanimous margin and directed that action be taken by  the General Court of 
Massachusetts. While the details of this Warrant Article are not specific to the 
details of the DOER proposal, it nonetheless illustrates a groundswell of 
dissatisfaction at local level with the inadequacy of state policy. This local 
groundswell spread across the state earlier this year and was instrumental in 
pressuring members of the state legislature to act on solar policy in legislation 
that the Governor signed on April 11, 2016. That legislation was still far from 
adequate, as is this latest proposal by DOER. There will certainly be another 
groundswell of local response this coming year if the comments and 
recommendations of MassSolar are not incorporated by DOER.

Mass Solar Comments are as follows:
1) It is crucial to create an interim program to fill the void between 
 the January 8th expiration of the SREC II program and the implementation 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.
 
