From:	Brian Kuhn <Brian.Kuhn@aeronauticawind.com>
Sent:	Wednesday, October 26, 2016 5:17 PM
To:	SREC, DOER (ENE)
Subject:	Comments on what comes after SREC II

DOER:

Associated Energy Developers is a MA-based renewable energy design/build contractor.  At this time we 
control or have built out nearly 10MW of solar projects in the state, ranging from 25kW to more than 
1.5MW.  We are focused on the commercial/industrial marketplace. 

We wish to make a small number of comments for consideration by DOER regarding the end of the SREC 
II program and the upcoming ‘Straw’ proposal for a Feed-in-Tariff:

1.	Like dozens of MA companies, we have recently expanded our company by hiring a number of 
new employees, and had been considering additional hires over the next 6 months.  However, 
we are now considering laying off these same people, due to what we believe will be a ‘lapse in 
time’ that will occur in the marketplace between programs.  Between the time the SRECII 
program effectively ends on January 8th (and one could argue that it has ended now if you have 
not received an ISA) and the time that new rules can be established and codified for a new FIT 
program, we will be in ‘limbo’ from a sales point of view.  Even today we cannot in good faith 
contract for new projects, since we do not know which program our customer will fall into, or 
what the formulas will be to reward their investment in a solar system when built out during 
next year.   Given that it could take 6 months or more to completely institute new regulations, 
this creates a real hardship to promoting solar systems and maintaining employment.  The 
problem is compounded by the time it takes (60+ days) to obtain an ISA from the utilities for 
systems over 25kW.   In order to avoid this lapse in the industry and maintain momentum, we 
strongly suggest that entry into the SREC II program – at non-discounted SREC factor values 
(ie: no .2 decrease) - be extended UNTIL the new program rules are ENACTED, and not at some 
arbitrary date while they are being discussed.

2.	We are very concerned about the statements that FITs may ‘take the place’ of net metering in 
the future.  The ability to assign Net Metering Credits to other accounts, and thus monetize the 
value of that energy, is a key element in designing larger systems that can take advantage of 
economy of scale, and supply more than the on-site load.  Without a replacement for the 
assignment of Net Metering Credits, it would appear that we will lose the mechanism for project 
owners to ‘get paid for’ net excess generation.  This is most critical for sites that will function as 
a Community Shared Solar (CSS) facility, where the current ability to contract for and transfer 
net metering credits is one of the two basic methods of forming a CSS project (with the other 
being joint ownership in the system).  How would a CSS system even function under a FIT, 
without the ability of the Host to ‘share’ the credits or energy made?  If they were to only able 
to receive FIT payments, then presumably all CSS systems would need to use the ‘shared 
ownership’ method to work, where the CSS members are paid in the form of cash distributions 
received from the CSS?  It would appear that CSS is receiving a large amount of attention in this 
new policy straw proposal.  If so, a replacement for net metering is needed, and making the 
details of such a program available early on is even more important, especially when considered 
in light of our first comment.

3.	Lastly, we are concerned that the proposed FIT, which in effect places a consistent  ‘cap’ on the 
value of similar solar power project types across the state, runs counter to a competitive 
marketplace. Because of the underlying value of site’s retail energy being ‘subtracted’ from the 
FIT, a developer of a ‘Building Mounted, Low Income CSS project’ (for instance) located in 
Western MA would earn the same tariff, but much more savings, as a similar project located in 
more energy expensive Cape Cod.   While the straw proposal may seem egalitarian across the 
state, and perhaps aligns with the goals of the entire solar proposal, the result will be that those 
participating in solar projects in higher cost energy areas will recognize less incentive from the 
FIT.  We may, in fact, already have many places where the current energy costs are at parity 
with or ABOVE the suggested base fit payment, so that it offers no assistance at all.  How does 
that promote solar equally across the state?  Should a system owner on Cape Cod receive no 
incentive, while others are paid greater FITs?  This does not seem even handed, and also seems 
to disfavor solar competition in high priced markets.

4.	On the positive side, we do like many of the aspects of a FIT vs the SREC programs, namely the 
‘ease of understanding’ for the customer, elimination of the need to sell RECs in another 
marketplace by small operators, and the ‘bankability’ such a program should offer.  But it would 
seem that there is a lot to consider in getting this right, so that Massachusetts maintains its 
position as a leader in the solar markets.  Creating a workable ‘bridge’ from one program to the 
next is paramount for continued success.  Starting and stopping programs is a recipe for 
disaster, as we’ve seen in this industry for decades.


Thank you for your time and all the good work you have done to date.

Regards,     

Brian D. Kuhn
Founder, Director of Development
Aeronautica Windpower, LLC
Associated Energy Developers, LLC
11 Resnik Road
Plymouth, MA 02360
www.AeronauticaWind.com
http://www.assocenergy.com/
www.Wind4Water.org
UMass Wind Program Turns 40

800-360-0132
508-364-9489 - cell 
skype: brian.kuhn144

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