From:	jan@westwood-statistical-studios.org
Sent:	Wednesday, October 26, 2016 6:18 PM
To:	SREC, DOER (ENE)
Subject:	comments regarding "Next Generation  Solar Incentive Straw Proposal"

Dear Commissioner Judson, and colleagues:

Thank you for this opportunity to comment on "Next Generation Solar Incentive Straw 
Proposal". 

While there are concerns by the solar industry on how a change in the system of 
Massachusetts incentives will affect rates of installations in the near term, my concern is 
for the longer term. From my perspective, despite the self-congratulatory language of 
the DOER's presentation regarding rates of take-up of solar in Massachusetts, 
Massachusetts has yet to fully embrace the zero Carbon energy future it needs, and to 
benefit from the economies of energy solar will offer beginning now, but dramatically 
being available in the 2020s. When combined with energy storage of various kinds, 
including storage as a business as well as residential storage, current projections put 
unsubsized cost per kWh of solar+storage in the home over system lifetime at or 
below cost of energy transmission beginning in 2022.

 

Wind, especially onshore wind, has its own highly competitive (business) experience 
curve, but, in terms of siting, transmission and conversion losses, and provision of 
capital for construction, residential and small scale commercial solar PV has huge 
advantages over alternatives, even if it is a part-of-the-day solution to providing energy. 
A significant portion of Massachusetts energy needs could be provided by the available 
``fleet'' of homes with good roofs and space on residential land, if they were incentivized 
properly. For instance, there is no need to even discuss land use if existing roofs are 
being repurposed for solar. 

While I understand DOER operates under the constraints of M.G.L. Chapter 164, it 
is critical that DOER and the Massachusetts legislature understand the repercussions of 
failing to ``get with the program''. Solar PV is a technology, not an energy resource. To 
maintain `solar net metering caps', or any such restriction will simply incentivize 
individuals and businesses to take advantage of the benefits of this `program' on their 
own, that is, hoard electrons, denying the grid and the Commonwealth the value of solar 
and distributed energy. In fact, one of the most specific comments I have regarding the 
``straw proposal'' is that it seemingly fails to reflect the full value of solar in the 
schedules presented. 

This will happen because, as solar+storage costs diminish, the marketplace will provide 
products which facilitate the isolated residence in their defection. This has happened in 
Arizona where, under fees discrimination against solar, the marketplace is providing 
standalone air conditioning units powered by solar+battery providing and using energy 
the grid never sees.

I am no fan of net metering. I would much prefer two accounting channels, a charge for 
use, as is usual, and then a revenue stream back to the generator, treating each 
residence or business or community solar or other generator as if they were a generator 
to the utility. My reasons concern energy efficiency: There is good evidence that 
residences who offset their energy use via net metering are sloppier in their use of 
energy. On the other hand, failing to reward small generators for the full benefits their 
collective contributions provide the grid invites either clever arbitrage arrangements by 
creative businesspeople, or incentivizes small generators to leave the grid altogether, at 
least for a substantial portion of the energy they need. 

Technical assessments from the IEEE Power Engineering Society and Karl Ragabo, a 
recognized decentralized energy expert, put a challenge to grid stability at a minimum 
solar + wind penetration of no less than 14%. (And we are quite a distance from that.) I 
would also suggest that if Massachusetts utilities do not know how to build a grid which 
can accommodate a large amount of varying, decentralized energy, or do not want do to 
so, for financial reasons, DOER and the legislature should change regulations so the 
free marketplace can innovate on its own to solve this problem, by rapid introduction of 
microgrids, commercial storage, and regional grid management solutions.

We need no more reminder of how far Massachusetts needs to go than the recently 
released U.S. Environmental Protection Agency Green Power Partnership National Top 
100 organizations. While some of the companies on that list have facilities in 
Massachusetts, these do not contribute to their qualification for this list because 
Massachusetts has no substantial zero Carbon energy assets to offer such 
companies.  Moreover, you'll find various state governments, and even cities on that list. 
No company headquartered in Massachusetts is there. No municipality of 
Massachusetts is there. 

Massachusetts is at a crossroads in choices for its energy supply. It's time the 
Commonwealth and DOER recognized that solar energy, especially PV, is a key 
component of that.

Thank you.

--
Jan Galkowski (o°)

607.239.1834 [mobile]
607.239.1834 [home]

320 Dover Road
Westwood, MA 02090

jan@westwood-statistical-studios.org
empirical_bayesian@ieee.org
http://667-per-cm.net

Westwood Statistical Studios
... specializing in environmental statistics,
often doing pro bono consulting

member, 

... American Statistical Association
... International Society for Bayesian Analysis
... Institute of Electrical and Electronics Engineers
... American Meteorological Society
... Ecological Society of America
... American Association for the Advancement of Science
... American Solar Energy Society

