From:	King, Amanda <aking@bentley.edu>
Sent:	Friday, October 28, 2016 5:01 PM
To:	SREC, DOER (ENE)
Cc:	Knapik, Dan (ENE)
Subject:	Bentley University Comments on State Solar Incentive Straw Proposal

Dear Sir or Madame,

As the Director of Sustainability and Special Advisor to President Gloria Larson at Bentley University, I’m 
submitting comments on the Massachusetts Department of Energy Resources’ upcoming solar incentive 
regulations. 

Bentley University is a signatory to the Presidents’ Climate Commitment and as such we have set 
aggressive goals for greenhouse gas reductions on our campus. We are currently working on two solar 
installations for our campus in Waltham, MA. The first project is a 500KW system that spans eight 
rooftops. The university has a power purchase agreement in place for this installation, designs have 
been completed and we have received interconnection approval from Eversource. The second project 
will be constructed on the roof of Bentley’s planned multipurpose arena (which houses a hockey rink). 
This system is expected to be approximately 500KW in size. The university does not currently have 
power purchase agreement in place for this installation as our financier is awaiting clarification on the 
state’s solar incentives program. The solar installation on Bentley’s multipurpose arena would provide 
40% of the arena’s annual electricity needs and is a critical component to the LEED Gold certification 
that we are seeking for the building. With a couple of minor design changes, we may be able to achieve 
LEED Platinum certification, but this hinges on our ability to secure a PPA for the rooftop solar 
installation. Our installation goal is November, 2017 for the arena solar project.

The eight-rooftop project was unfortunately caught up between the SRECII and SRECII emergency 
extension programs. We were ultimately unable to complete installation by January 1, 2017 and are now 
waiting for the next incentive program to proceed with the installation. This project has been a 
herculean effort on the parts of Bentley’s Office of Sustainability and Facilities Management personnel 
who have been working on it since October, 2013. Bentley’s students, faculty, staff and alumni are all 
looking forward to finally seeing the project come to fruition. Timing is critical for this project as our only 
construction window is between May and August, when buildings on our campus are mostly empty. 
Installing solar panels on our residence hall roofs is not feasible during the academic year when campus 
is quite busy; construction on eight buildings could pose an increased safety risk for our students. Given 
the current market uncertainty the university and our financiers on this project will have to make 
decisions about this installation based on DOER’s “straw proposal.” As such, we’d like to voice our 
support for the current 15 cents per KWH /15 year rate and hope to convey the urgency for institutions 
of higher education, like ours, to have assurance on this price, timeline and incentive program as soon as 
possible. We fear that reductions in the cost per KWH or the 15 year time horizon are likely to have 
significantly negative impacts on both of our solar projects.

Bentley university is eager to install both systems discussed above, as they will help us meet our public 
carbon footprint reduction goals. Furthermore, both installations provide an opportunity for us to use 
the campus as a “living lab.” Our students will study the electricity production and cost-savings from the 
systems and will learn about renewables financing. Projects like this provide our students with hands-on 
learning opportunities and help shape their careers after graduation. At our university, sustainability is 
an institutional initiative, visible in our operations, our academics and our career services work. 
Sustainability is included in the mission of our university because we know that “triple-bottom line” 
thinking is imperative for business and we aspire to prepare our students to be ethical and socially 
responsible business leaders. 

We appreciate the opportunity to comment on the Massachusetts Department of Energy Resources’ 
upcoming solar incentive regulations and thank you for your time.

All my best,
Amanda King

Amanda King, MEM, LEED AP
Director of Sustainability and Special Advisor to the President
Bentley University
175 Forest St., Rauch 322
Waltham, MA 02452
781.891.2252 (direct)

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