On September 23, 2016, the Massachusetts Department of Energy Resources (DOER) presented its Straw Proposal to outline its vision for the next solar incentive program for the state. The DOER is proposing to shift away from the state’s successful SREC program, which has created one of the largest and most robust solar markets in the country.
Under the DOER’s proposal, a declining block feed-in-tariff would be established in regulated utility territories, and a separate program would be created for municipal light districts. Moving away from the current market-based framework will impose a substantial transition burden and introduce new costs to participants. The shift to a completely different program will have a negative impact on the viability of the solar industry in the interim and poses uncertainty moving forward.
Massachusetts has installed more than 1,200 MW of operational solar capacity to date and was ranked 2nd in the nation in total solar industry employment in 2015. Replacing the current market-based framework with a declining block feed-in-tariff will not only be costly to all stakeholders, but it will also fail to satisfy the DOER’s objective to “provide clear policy mechanisms that control ratepayer costs and exposures”. By imposing this new and complicated model, the DOER will force the state’s many market participants to manage, understand, and abide by multiple programs at once. This will undoubtedly increase soft costs and increase administrative burden across the industry.
In contrast, establishing an SREC-III program would allow the state’s solar industry to continue relying on a market-based policy to set incentive levels and forge ahead on its path to a stable, equitable, and self-sustaining solar market. By making adjustments to SREC factors, market sectors, the SCCA and SACP, the Commonwealth can continue to benefit from the successful SREC model and preserve the progress it has made since SREC-I was implemented six years ago.
SRECTrade encourages all stakeholders in the Massachusetts solar market to submit comments in support of a smooth transition to another successful SREC program. Comments can be submitted to the DOER via email at DOER.SREC@state.ma.us and must be submitted by this Friday, October 28th.