From:	Eric Grunebaum <eric@cambridgeenergyadvisors.com>
Sent:	Friday, October 28, 2016 5:34 PM
To:	SREC, DOER (ENE)
Subject:	Comments on Next Generation Solar Incentive Straw Proposal

Thank you for your consideration of the following comments:

1. A more graduated incentive from 25 kW – 1,000 kW
The current design paints commercial projects with an overly broad brush, as if they are all in the same class. In both the 
25 – 250 kW and the 250 – 1,000 kW frameworks the proposal provides the same incentives for a very broad ranges and 
scale of projects which are fundamentally different.

250 kW – 1,000 kW
Systems at the top end of the scale, in the 1,000 kW range, are essentially small utilities, often on green-fields, while many 
projects at the lower end of the scale, closer to 250 kW and in the middle range, 500 –750 kW are typically rooftop 
systems on commercial and industrial buildings, for larger non-profits (universities and hospitals) and on large apartment 
and condo buildings,.

Thus I would propose two additional divisions between 250 –1,000 kW topping out at the same incentive however. I have 
seen many commercial rooftop owners who have potential for facilities greater than 250 kW, yet significantly less than 
1,000 kW, who are not able to take advantage of the economies of scale available at higher end of the range as you get 
closer to 1,000 kW. These projects often not economic and fail to advance with today's program, although for many 
reasons they are ideal (close to load, on roofs, etc.)

25 – 250 kW
As above, many of these sites are exactly where solar is most beneficial – on rooftops, rather than on green-fields – and 
much closer to load, or indeed right at load. Projects in the 25 – 250 kW range are often in dense urban areas and are on 
small commercial buildings, non-profits, or apartment buildings and have in-effect negative economies of scale due to 
their intrinsic complexity, even when compared with single family homes (which, although smaller, have single owners 
and a simple path to tax equity monetization.)

Summary:
Thus, for the smallest "commercial" projects, I would recommend adding incentives so that more projects in urban and 
complex locations, closer to load are built. 

In the 250 – 1,000 kW scale systems, I suggest working down towards the $0.18 for the top scaled projects as envisioned 
in the straw proposal, but with finer divisions between the two cost points. 

In short, the concept is to avoid treating smaller "commercial" with the same brush as far larger systems which benefit 
from far greater economies of scale. I suggest the following incentive categories:

25 - 250 kW        $0.26
250 - 500 kW      $0.24
500 - 750 kW      $0.21
750 - 1,000 kW   $0.18

In the Straw Proposal, there is precedent for a more graduated support like this, as it is similar to the graduated support for 
CSS facilities which increases with each additional 25% of low-income off-takers.


2. 25 kW Three Phase Limitation
A second aspect of the current policy which was not addressed in the Straw Proposal is the 3-phase requirement for 
facilities up to 25 kW. I would like to provide a specific example where this limitation is in conflict with allowing for 
small-scale commercial systems, which I assume is its very intention. 

The example is a small house of worship in Cambridge (which I'm on the board of.) The small temple on Magazine St. can 
accommodate a system of about 20 kW on the roof and it would be well matched to load (about 75%.) However, the 
connected buildings are former homes and thus are single phase, which puts the project at an unnecessary disadvantage. 
Why have a 3-phase requirement at all? What purpose does it serve?

It's not clear to me whether the single phase vs. 3-phase distinction will have any bearing in the new program design, but I 
would ask you to simply eliminate it, as there are many other similar examples where small commercial projects are 
disadvantage because they are proposed for buildings which frequently are located in small commercial town centers and 
were originally built as residences and are single-phase (though today they are the homes for small neighborhood 
businesses, non-profits and houses of worship.)

Thank you -
Eric Grunebaum

-
Eric Grunebaum
Cleantech Business Development
 + Impact Investment
Cambridge Innovation Center, 1 Broadway, Cambridge, MA  02142 Cell: 617-304-5824
CambridgeEnergyAdvisors.com - Clean energy + impact investment advisory

