From:	Todd Fryatt <tf@ecasolar.com>
Sent:	Sunday, September 25, 2016 4:46 PM
To:	SREC, DOER (ENE)
Cc:	Judge, Michael (ENE)
Subject:	comments on Solar Straw Proposal after Federal Reserve 9/23

Greetings:

I would like to provide some feedback and comments for the record as follows:
*	Behind the meter customer sited systems should receive a location based adder.  There is 
no incentive to include Massachusetts customers in this declining block program.  There 
should be a location based adder for on-site generation behind the meter.  Similar to 
SREC II which gave behind the meter systems a strong Market Segment B (.9 SREC 
Factor).  
*	Please maintain the same requirements to receive a declining block incentive as you did 
with SREC program.  Consistency here is useful for all.  Entry to the program is a highly 
coveted state incentive.  All applicants must possess basic entitlements; including a fully 
executed Interconnection Services Agreement, Non-Ministerial Permits and Site 
Control.  Its imperative the Applicants meet these standards if they want to take up 
valuable state incentives and queue space.  If these cannot be demonstrated its not fair to 
take away from other mature projects which are established.
*	Projects that receive access to a declining block award must have a deadline for being 
mechanically complete.  Nine months is too aggressive.  12-15 months is more 
reasonable given all the complexities with utilities, batteries, CSS and low income 
factors.
*	The 5MW AC system size cap makes sense.  There is no need to go larger than 
this.  Beyond 5MW AC, you will have a few companies and a few projects dominating 
the blocks.

 


-- 

Todd E. Fryatt
ECA SOLAR
30 Newbury Street, Third Floor
Boston, MA, 02116
Direct: 617-750-7159

