From:	Brian Hebeisen <peru_boy@hotmail.com>
Sent:	Friday, October 28, 2016 11:55 PM
To:	SREC, DOER (ENE)
Subject:	Comment on Next Generation Solar Incentive Straw Proposal

Commissioner Judith Judson and Director Michael 
Judge                                                                October 28, 2016 
Department of Energy Resources 
100 Cambridge Street, Suite 1020 
Boston, Ma. 02114
 
Dear Commissioner Judson and Director Judge,

I would like to thank you for all the hard work on the proposal for the new solar incentive plan. I 
believe that solar is a key component in solving the pressing problem of global warming and 
meeting Massachusetts' related clean energy  goals. The goals set out in the original global 
warming legislation were a bold response to global warming. A new bold response is needed to 
take the next steps towards meeting the carbon reduction set out in that legislation. The 
impacts of global warming are even more present, obvious and dire than when the original 
legislation was passed.

I believe the proposal for the new solar incentive program is generally good but with some 
major issues needing to be addressed. Others have stated those issues more eloquently but I 
would like to add my voice to the key issues.

An interim plan needs to be in place (most likely an extension to SREC II) and net metering caps 
raised (or removed) to avoid a gap in incentives and in consequence a halt in (large scale) solar 
development.

The initial incentive values should be larger and based on market values. 

Incentives should generally decline over time but based on market values rather than an 
arbitrary 5%.

The program should not be limited in total capacity but should be evaluated annually or 
periodically for solar contribution to overall carbon reduction goals. I believe that meeting the 
carbon reduction goals will require a much larger solar build out than specified in the 
proposal. Also, having a longer term for this incentive program will prevent the disruption 
caused by the start-stop of incentive programs.

Siting should not be more restrictive than for other development purposes such as residential 
and commercial buildings. Also, benefits of solar fields for secondary nature or agricultural uses 
should be considered in consultation with conservation advocacy organizations - as Audubon 
helped develop guidelines for wind siting.

Community solar should be especially incentivized due to its special place as a growth field for 
solar and method to make solar available to all. It also tends to have higher costs due to the 
financing and customer service  retail model.

These comments are not comprehensive or very detailed and are intended to show support for 
robust solar development in the coming years. I would suggest that representatives of all solar 
stakeholders be actively involved in the detailed planning of this program going forward.

Thank you for your consideration.

Best regards,

Brian Hebeisen
617-642-7478






