Pope Energy Comment Letters

Read Pope Energy’s Policy Letter on Electricity Generation in Massachusetts

Governor Charlie Baker
24 Beacon Street
Office of the Governor
Room 280
Boston, MA 02133

Re: Solar Generation as a Percentage of Massachusetts Consumption

Dear Governor Baker:

The creation and rollout of the SMART program is an example of good government, and you
should take pride in the manner in which DOER sought industry and stakeholder input in an
effort to establish a sustainable solar program demanded by the legislature. This is not an empty
compliment. My companies have been doing business in the Commonwealth since 1979, and
as a businessperson, I have often felt that I was dealing with a kind of undercurrent akin to a
Troop E and MBTA parking lot revenue management problem. So, thank you for attracting and
retaining good people in place to innovatively create and implement good solar public policy.

The good news is that, because Massachusetts has managed the SREC I and II programs in a
consistent and reliable manner, investors have confidence to invest in Massachusetts’s solar
projects. The bad news is that because of that confidence, the 1600 MW SMART program,
which has taken eighteen months to create, will nearly be oversubscribed before it starts in
National Grid and Unitil territories.

While it may be expected that a nascent industry will have fits and starts due to being a new,
disruptive change from the traditional energy market, the choppy transitions between SREC I
and II, combined with the on-again, off-again availability of net metering, has been brutal on
small and medium-size companies trying to build a solar business in Massachusetts.

Larger companies simply move to another state, but in Massachusetts, small and medium-size
companies are very heavily impacted by a lack of steady and consistent solar policy.
Businesses see future demand due to legislated renewable compliance obligations, but they are
unable to access this demand, and dependably build a business around it, because of choppy
policy implementation. Among small and medium-size businesses, there is definitely a feeling of
“Here we go again…” as the SMART program is oversubscribed within months of opening.

Designating that twenty percent (25%) of electricity generation in Massachusetts will come from
solar PV coupled with storage by 2030 is preferable to expanding the existing program by
another 1,600 MW. This mandate will give small and medium-size businesses a clear path to
grow, employ people and make an increased impact on the Massachusetts economy through
2030.

Great cities like Fitchburg will not be shut out of developing solar projects if Massachusetts is
focused on achieving a percentage of its electricity from solar as opposed to a finite 1,600 MW
program with each utility sharing a portion of that program based upon their percentage of
supply. Once the SMART portal opens, within a week or a couple of months, the Unitil allotment
under SMART will be developed, thereby locking out Fitchburg from further development for
years.

DOER acknowledges that the price suppression effect of solar generation lowers the wholesale
cost of energy, so ratepayers’ overall cost will not be paying for this transition. These cost
savings are in addition to other value of solar benefits.

Planning for compliance of the Green Communities Act, a new RPS commitment of 2% per year
until 2030, Kane vs. DEP, system planning within ISO-NE, integration of energy storage within
ISO-NE, Smart Grid planning by the utilities will be greatly enhanced by a commitment to install
25% of solar generation by 2030.

With all of the compliance obligations that the Governor’s office is charged with managing, if it is
within the authority of your office to establish a solar policy that states that 25% of
Massachusetts electricity consumption shall be supplied by solar generation by 2030, you
should do so and keep the jobs, careers and energy generation in Massachusetts.

Otherwise, the Baker Administration should request that the legislature adopt this policy as a
measure of meeting the compliance obligations passed by the legislature as well as maintaining
a sustainable solar industry in Massachusetts.

Announcing this program after the SMART portal is open on November 26, 2018 would give a
clear signal to the industry, the investor and finance communities, and other stakeholder groups
that solar in Massachusetts is here to stay as an integral part of our economy.

Thank you for your consideration.

Best Regards,
Doug Pope
President

Pope Energy Offers Additional Comments on SMART Guidelines

Michael Judge

Director, Renewable & Alternative Energy Division Department of Energy Resources

100 Cambridge Street, Suite 1020

Boston, MA 02114

 

Dear Mr. Judge:

The manner in which DOER has solicited stakeholder input, hired outside expertise, and rolled out the program design of the SMART program is a best-in-class example of good government. It is the actions of the legislature in the Green Communities Act, Chapter 75 of the Acts of 2016 and the consistency in which DOER has handled the transition between solar programs that, despite the absence of a functioning SMART program, has created a confidence in the market that, at the end of the day, Massachusetts will do the right thing to create a long-term sustainable solar program in the Commonwealth. If DOER gets the pricing and program design right, the SMART program will be an enviable program that other states should consider adopting.

While DOER is in the process of creating a more bankable solar program, the above mention of appreciation does not mean the program is perfect by any means. Like any growth-control instrument, the 1600 MW program design creates its own level of unnecessary complexity, as opposed to establishing a long-term program through 2030.The declining block mechanisms based upon past rapidly declining solar materials and labor assimilation costs are running into national tariff programs, rising inflation and a strong economy. Combine rising solar cost with skyrocketing   interconnection cost and the usual high land entitlement cost with the declining block mechanisms, and the solar industry will be experiencing the same on-again, off-again availability of solar development experienced during the SREC and net metering programs. This comment letter will attempt to mitigate the shortcomings of the SMART programs for larger ground mount systems.

225 CMR 20.00 Regulatory Provisions Specific to Agricultural Solar Tariff Generation Units

Despite the best of intentions, the Agricultural Solar Tariff provisions appear to have been designed to preserve rather than create more farmland. The SMART program and its Guidelines should specifically encourage the creation of more farmland and all the economic and community benefits that attribute to a locally grown food industry as defined in Chapter 61A sec. 1 & 2.

When new farmland is created or returned to agricultural use, this would mean that the SMART guidelines would allow for the development of solar systems 5MW per parcel in size with no subtractors and the Agricultural Solar Tariff would ensure retention in agricultural use for 20 years.

Using the capital investment stack of installing solar PV plus the Agricultural Solar Tariff adder would accomplish the following:

  1. The existing farm industry needs more farm-related income to make their operations viable. Differing business models will be developed, but the existing farming, farm supply, landscaping, site contractors, equipment suppliers will be the first to be called upon to create, develop, plant, harvest and maintain these dual-use businesses.
  2. SMART creation of farmland will combat the breakup of family farms due to non- farming family estate transition issues.
  3. SMART Agricultural tariff provisions will ensure that solar owners develop business plans and relationships to maintain the land in bona fide agricultural use for 20 years. Not only will SMART create a renewables industry, it will broaden and strengthen the agricultural sector. As an example, every 100MW worth of solar projects at an average of 40 acres per 5MW solar project could add over 800 acres of farmland into the Massachusetts farm inventory.
  4. SMART, while innovative, has detractors and first among them is the cost of interconnection. Larger projects combined with some agricultural revenue will help mitigate some of those costs.
  5. SMART creation of farmland, particularly as projects are aggregated to common solar project owners, will drive innovation in organic farming, which requires soils to have no prohibited substances for three years. Other standards call for distances to be within a 300-mile sector radius of the site, which for Massachusetts would also include the New York City and eastern New York state markets.
  6. Co-locating solar renewable energy with greenhouses could be not only a competitive advantage but also a grid-systems benefit, pairing high-energy users in the immediate proximity to renewable generation.
  7. The SMART tariff will have no inflation or revenue increases for 20 years. This means that the systems degradation rate of 0.005% plus a 1.5% inflation rate results in a 2% per year degradation in purchasing power per year for systems maintenance and repair. Dual use of this land will assist in the continued viability of the land dedicated to solar In 20 years, land dedicated to solar will be part of our grid infrastructure and will need to have continued economic viability. Having project scale size and a second source of revenue is a part of such continued economic success.

 

225 CMR 20.02: Definitions

Agricultural Solar Tariff Generation Unit. A Solar Tariff Generation Unit located on Land in Agricultural Use or Prime Agricultural Farmland that allows the continued use of the land for agriculture.

Recommendation:

The Guidelines should accommodate the creation or the return of land to agricultural use or the definition in 225 CMR 20:02 will need to be changed.

The Agricultural and Land Use Guidelines should recognize land returned to agricultural use as valuable land of statewide importance and therefore should recognize NRCS, USDA 657.5 Identification of Important Farmlands (2) (c) and (d). Prime farmlands as defined within the federal definition are very difficult to achieve, inhibits innovation and adds a layer of complexity whose definition is beyond state control to define whereas 657.5 (2) (c) & (d) are determined by State agencies. NRCS, USDA 657.5 (2) (c) and (d) (below)

(2) Specific characteristics of unique farmland. (i) Is used for a specific high value food or fiber crop; (ii) Has a moisture supply that is adequate for the specific crop; the supply is from stored moisture, precipitation, or a developed-irrigation system; (iii) Combines favorable factors of soil quality, growing season, temperature, humidity, air drainage, elevation, aspect, or other conditions, such a nearness to market, that favor the growth of a specific food or fiber crop.

(c) Additional farmland of statewide importance. This is land, in addition to prime and unique farmlands, that is of statewide importance for the production of food, feed, fiber, forage, and oil seed crops. Criteria for defining and delineating this land are to be determined by the appropriate State agency or agencies. Generally, additional farmlands of statewide importance include those that are nearly prime farmland and that economically produce high yields of crops when treated and managed according to acceptable farming methods. Some may produce as high a yield as prime farmlands if conditions are favorable. In some States, additional farmlands of statewide importance may include tracts of land that have been designated for agriculture by State law.

(d) Additional farmland of local importance. In some local areas there is concern for certain additional farmlands for the production of food, feed, fiber, forage, and oilseed crops, even though these lands are not identified as having national or statewide importance.

Where appropriate, these lands are to be identified by the local agency or agencies concerned. In places, additional farmlands of local importance may include tracts of land that have been designated for agriculture by local ordinance.

Continued restriction on the use of Prime Agricultural land in both the Agricultural and Land Use Guidelines is short-sighted, inhibits innovation and will not create the kind of impact the 1600 MW SMART program and its successor is capable of accomplishing.

Existing Guidelines:

Guidelines No. 3: all Agricultural Solar Tariff Generation Units must demonstrate that the maximum sunlight reduction from the panels on every square foot of land directly beneath, behind and in the areas adjacent to and within the Agricultural Solar Tariff Generation Unit’s design shall not be more than 50% of baseline field conditions;

Guideline No 4: fixed tilt designs shall include a minimum four feet distance between each panel(s) in order to avoid full shade beneath and behind each row of panels; single- and double-axis tracking systems must demonstrate the 50% sunlight reduction maximum can be achieved without the minimum four feet distance;

Recommended: Recognize Differing Approaches

The Guidelines should recognize differing approaches to solar panel and agricultural land-use design. The drawings completed by Solar Design Associates indicate differing designs that meet or exceed the requirements stipulated by SMART. Please find attached comparison between SMART 4’ Program Agricultural Racking, Industry Standard Ground Mount PV Racking Strategy and our recommended Improved Agricultural Racking Design.

The “Improved Agricultural Racking Design” as indicated by the SDA drawings holds the row spacing farther apart, allowing more unshaded areas for agricultural use and facilitating the use of machinery for the harvesting of crops. The expanded row spacing will also allow for the installation of lower profile greenhouses as the industry concept matures.

The current SMART recommendation of holding the individual panels four (4’) feet apart is fine in theory for certain discrete applications but is in general not economically viable and limits innovation.

The current guidelines make no accommodation for shade tolerant crops, substitution for certain requirements for the introduction of bees, or allowances for greenhouses and other innovative uses and business plans not yet explored.

Agricultural Scale:

According to MDAR, the average farm produces $63,470 on 68 acres of land. Out of 7,755 farms consisting of 523,000 acres, 6,500 farms earn less than $50,000 per year. To be viable and drive innovation, the SMART program should encourage the re- creation of agricultural land and to give it scale to compete and deliver products to market. Two (2MW) megawatts of solar, which will consume about ten (10) acres of land under the current guidelines, is not a farming business at ten acres but a hobby. SMART agricultural development should not be competing with the retail U-Pick farms who provide a day-trip entertainment kind of experience. SMART agricultural dual-use solar projects should be commercial in nature and as such need scale to compete. Why would a developer build a 5MW solar project (30-40 acres) and only install 2MW (10 acres) worth of dual-use agricultural solar racking? It would be a waste of resources and opportunity.

Out of the 5,284,480 total acres comprising the Commonwealth of Massachusetts, currently 523,517 acres are in farmlands or 10% of the land area. In 1920, 25% to 37.5% of the land (or 1.3 million to 1.9 million acres) in Massachusetts1 was in agricultural use, giving rise to the observation that all of the stonewalls that we see in the woods and forest were once farms.

Dual-use SMART Agricultural Solar should be allowed to recreate farmland with no subtractors at the 5MWac per lot project size and be expected to meet the MDAR expectations of a viable agricultural plot of land.

Typical of farm customers we speak and contract with, there is a family of four siblings in the SEMA load zone who have a farm where only one member still raises cattle for sale. The other family members respect his wishes to remain farming the land but want to extract value off the land without selling the land and look to a solar land lease to accomplish those goals. When the farming member was inquired if he would like to take advantage of participating in the SMART Agricultural Solar program, he jumped at the chance, saying he was not restricted by barn size or water, but feed stock (grazing & hay) to be able to afford to raise more animals. The family has 20+ acres cleared for pasturelands and we would need to clear another 25-30 acres and return that land to pastureland. The project would require the SMART program to allow the re-creation of farmland to 5MW with no subtractors under Land Use Category 1.

Our firm has another farm family with four siblings in NEMA Boston that is breaking up a 400-acre farm, putting retirement housing on one 200-acre piece and 5MW of solar on treed land not being used for farming on the remaining 200-acre agricultural piece. This project should have the ability to return this land not used for farming into agricultural use. Otherwise the land will be sold for house lots.

Change Land Use Designation: Land returned to agricultural use should be viewed as a Category 1 resource.

For financing purposes, DOER and MDAR will need to recognize business plans because the first year may not yield a harvestable crop, depending on the time of year in which the final commercial date of operation is achieved.

In addition, it is not clear how MDAR would recognize long-developing crops like tree farms, vineyards, and even perennial crops like asparagus which takes 3-5 years to mature.

Additional Provision 6.

For financing and project viability projections, the two (2MW) megawatt Agricultural Solar limit needs to be raised to 5MW immediately and be included within the first two declining blocks.

If we are lucky enough to get into Block 2, we should have the ability to restore a gravel pit currently in a Solar Overlay District to an agricultural use for a 5MW project or have the ability to plan today for such eventuality in Block 3.

Land Use: Solar Overlay District and Other Allowed Zoning Regulations.

Each municipality will have its own approach to zoning and site plan review regulation processes. If a municipality has a Solar Overlay District or other permissive solar zoning regulations, but requires a “Special Permit” or a variance, waiver or other discretionary approvals, such processes should not be a fatal flaw that disqualifies a STGU from a Category 1 classification.

Land Use: Multiple Product Sites:

The Guidelines should not discourage in any way canopies, roof mount and ground mount systems from existing on the same site and being metered potentially separately from one another, depending upon application.

Base compensation rates should apply upon solar type – Building Mounted, Ground Mounted, Canopy Mounted or potentially Floating Mounted systems.

Land Use: Contiguous Parcels

This is an example of growth control adding a layer of unnecessary complexity due to a lack of regulatory commitment. The 1600MW SMART program is reportedly oversubscribed before it even starts. The contiguous parcel rule will complicate financing and securing tax-credit participation, as it will span differing tax-credit schedules from 30% in 2019 to 26% in 2020. Additionally, cost will increase as total project cost is front loaded without the ability to complete project construction as well as increased project superintendence, management, general conditions and interest cost will be unnecessarily incurred.

If a developer has a 3-parcel project with 20-acre parcel, a middle 7-acre piece and a 5- acre piece of abutting land and high interconnection cost that requires mitigation by increasing project size, the 20-acre and 5-acre piece will be developed according to current guidelines leaving the middle 7 acres to be developed after commercial operation of the first systems. The middle 7-acre piece will be prepared, most likely with site work, underground piping, seed and planted waiting for the regulatory window to install the racking, panels and medium voltage switchgear all the while burning interest expense, project soft cost and a duplicate utility interconnection post-mechanical completion lead-time. This Contiguous Parcel rule is a tremendous waste of money and resources that should be removed when substituted with a larger policy objective under the SMART format.

Energy Storage Guidelines:

While this comment is outside the guideline parameters, energy storage systems envisioned to be paired with the SMART program should be expanded to take the place of pipeline requirements during peak periods in the winter and summer months as determined by the Department. Which is to say that DOER working with DPU and ISO- NE would, during the winter months when sunlight is diminished and the panels may be covered with snow, allow the storage devices to be charged during off-peak periods with grid or DG provided electricity and discharged as required by ISO-NE. Payments for delivery and energy but not demand would be charged and cost recovery and profit to the energy storage owner could follow a similar format as already established in approved utility tariffs.

Statement of Qualification: Bankable Instrument

The Statement of Qualification needs to clearly state for financing purposes the statements that provide assurance to access the Tariff, the base rate and accepted adders and qualification to receive such rates for twenty years in the instance of a commercial system.

We appreciate the opportunity to provide these comments and the time that your office extends to reading and acting on public comments.

Best Regards,

 

Doug Pope

President

Read Pope Energy’s Comment Letter on the SMART Program

Judith Judson

Commissioner

Department of Energy Resources

100 Cambridge Street, Suite 1020

Boston, MA  02114

Re: Pope Energy Comment Letter SMART Program

Dear Commissioner Judson:

We appreciate the fact that DOER has made the effort to engage stakeholders in the development of the SMART program. The SMART program will be a model program, providing jobs and solar development opportunities for three to four years, if you get the program and the compensation numbers right.

Pope Energy is a commercial and utility scale solar developer focused primarily on ground-mount solar PV projects.

Land Use:

20.02 Canopy Solar Tariff Generation Unit:

Allowed: parking surface, pedestrian walkway or canal.

DOER should be encouraging dual use of land. If a developer has a 5 MW project consuming 20-30 acres of land, the developer should be encouraged to install a solar canopy and search for a secondary use of the land, teaming with farmers to farm the land or developing other horticultural uses for the land, such as growing flowers or establishing vineyards.

Add under allowed uses: Solar canopies shall be allowed if the land under the array is returned to pasturelands, horticultural lands OR arable land capable of maintaining temporary agricultural crops, temporary meadows, or land under market or kitchen gardens. System size shall not exceed 5 MW per parcel.

20.06 (d) 4. Special Provisions for Agricultural Solar Tariff Generation Units.

Existing: 4. the Solar Tariff Generation Unit’s AC rated capacity is no greater that one (1) MW.

Farmers in Massachusetts struggle to compete with larger scale farms outside of New England. Please do not add yet another restriction on the success of Massachusetts farmers. Our direct experience with farmers is that they are using solar to assist in adding revenue to stay in the farming business.

Changes to 20.06 (d) 4.: Allow Agricultural Solar Tariff Generation Units to have a system size of 5 MW per parcel.

20.02 Greenfield Subtractor.

Add: Exception. Any parcel of land, or portion thereof, that would otherwise qualify for a Greenfield Subtractor pursuant to 225 CMR 20.07 (4) (f) will not be subject to such Subtractor if such parcel of land is returned to pasturelands, horticultural lands, or arable land capable of maintaining temporary agricultural crops, temporary meadows, or land under market or kitchen gardens.

20.05 (5)(e)(1)(b) Land Use and Siting Criteria.

(b) Category 1 Non-Agricultural:

Add: v. Previously developed gravel pits or quarries and blowdown areas directly damaged by tornados.

2. Category 2 Land Use.

Existing text:  b. is zoned for commercial or industrial use, shall be designated as

Category 2 Land Use.

Add: is zoned for commercial, industrial, or solar overlay use, shall be designated as Category 2 Land Use.

Many municipalities may desire to have solar PV developed on a property but do not desire to extend commercial or industrial uses to that particular parcel of land or area of the city or town.

5. (f) Performance Standards:

(f) Project Segmentation. This section deals with adjacent parcels of land unable to be developed until one parcel is first commercially operational.

This section creates great difficulty due to the fact that DOER does not have the cost and compensation of utility interconnection within the program. One reason for developing adjacent parcels is to mitigate the high cost of interconnection for larger systems.

If the SMART program is promulgated in June of 2018, project segmentation will make the development of adjacent parcels more costly.  This is due to two factors: 1) Federal tax ITC periods will be crossed increasing the cost of financing and 2) project carrying cost will be unnecessarily incurred for another year. As currently written, the federal ITC remains 30% until 2020 whereupon it drops to 26%.

The adjacent parcel rule is a form of growth management, preventing depletion of the 1,600 MW too early, which speaks to a larger issue. In light of the Grid Modernization process at DPU, the IMAP process at ISO-NE, satisfying Kain vs. DEP, meeting the goals of the Global Warming Solutions Act, why can the SMART program not have a longer program length and meet a percentage of Massachusetts consumption by 2030? The SMART program might last four years (with most companies thinking two years) with a wait-and-see position before the declining block makes projects uneconomical. Two years is an opportunity, but not something to build a company around.

Yesterday, a survey company representing the MassCEC called me. Their survey was all about energy jobs created in Massachusetts. As a principal of a firm that has employed many since 1978, it is difficult to make the representation to prospective employees that “if you do a good job, there will be a place in this company for you” based upon a two-year program length.

Utility Interconnection Fees:

While DOER may not have direct responsibility for interconnection cost issues directly, the department should be elevating the policy debate and establishing the policy direction as the SMART program is handed off to DPU.

Consideration of a larger solar program and greater distributed energy contribution to Massachusetts’s energy total consumption would most likely yield a determination that there are system benefits to increasing levels of distributed generation. The postponement of the Spectra Access pipeline and the delay of Northern Pass should spurn these discussions of a greater solar and DG program. Within this framework, interconnection cost could be defined per kW and a balance of the cost could be moved into a Grid Modernization framework rather than being borne by a single solar or DG project.

15. (5) Adder Caps. Adder capped at 320 MW across all Distribution Companies.

If you look at the adder categories, they all require additional cost, labor, material or marketing and customer acquisition in the instance of community solar. There are no economic indicators that these non-technology labor and/or material cost are going to go down. Are the Community Solar companies going to lay off their employees after the 320

MW cap is hit? Are the cost of traditional welding methods and cost of steel in solar

canopies going to come down? No. The base rates will not accommodate these costs now and there is nothing in the market that would indicate a decrease in traditional labor and material cost.

I disagree with others to reduce the value of the adder caps. That is a political accommodation not based in economic conditions on the ground. Labor, customer acquisition cost and material are not going to go down over time. Inflation, year over year, will make up for any efficiencies derived from greater volume.

If per customer acquisition costs do go down, it will be because of investment in technology, which will concentrate community solar aggregation to only a very few firms which may not be reflected in cost reductions in developer originated projects.

Please retain the value on adders and remove the proposed caps over 320 MW on adders. The adders should be uncapped through the entire SMART program.

15.(6) Miscellaneous

(6) Review of Compensation Rates: Every 400 MW Needs to be every 6-months.

The SMART program needs to have a provision for periodic review every six months to review cost due to global conditions, federal regulations and tax codes, interest rates, and rising interconnection cost. Projects having received Solar Program Administrator approval would have those tariff conditions grandfathered.

The Suniva bankruptcy and subsequent 201 filing with the US International Trade Commission concurrent with a global solar panel glut, followed by large Chinese and Asia RFPs, has created great uncertainty at this writing about the cost of solar panels as manufacturers cut production and seek markets of greater value than outside the USA.

A floor price of solar panels could be established at a price of $0.78 per watt, having a huge effect on the SMART program that has anticipated year over year price declines.

Review provisions should allow DOER to make changes to the size of the program without having to re-promulgate the regulations.

Soon the legislature and Baker Administration will be considering the impact of moving to raise the RPS requirement to 3% per year. Combined with the Spectra indefinite postponement of Access Northeast pipeline, a larger solar program should be developed.

6Month Review – Benchmarking Against Known Cost:

Solar Panels: Tier 1 solar panels pricing is easily obtainable, transparent and global forces on availability and pricing are well publicized.

Electrical Labor: The Mass. Department of Labor and Workforce Development  maintains regular Prevailing Wage schedules that are capable of being used as a labor benchmark in the absence of market surveys.

Interconnection Cost: Cost paid for utility Impact Studies and Interconnection Cost are capable of being made transparent for assessment purposes.

Adder Cost Review: Evaluating the effect of inflation CPI–Boston, steel cost, labor, companies servicing community and low-income solar and effect on jobs.

Regulatory Review: Effect of interest cost, tax policy, property / equipment taxes

Getting the Pricing Compensation Right:

We just made a proposal to a farmer who is getting older and wants to install solar to help maintain his ownership of the farm. Revenue for a 500kW system equals the base rate of $0.15 x 125% + $0.06 for an agricultural canopy totaling $0.24750, interconnection cost $59,000, yielding an IRR of 8%. The farmer is not going to build the project under the SMART program because why should he sign personally on a $1.6 MM loan that only yields a 20-year average net revenue of $17,000 per year? We could not offer community solar because we do not understand how revenue will be derived and what the cost of participating in community solar will be. This gets back to the fact that the base rate is not right. For smaller ground mount solar projects under 2MW, the SMART program is going to need IRRs of closer to 12% to attract investment.

Fourteen cents ($0.14 per watt) will work on larger projects only if the interconnection costs are not too high ($0.11 per watt), entitlement conditions are not excessive, and the Subtractors are removed if the land is returned to pasture, horticultural, or arable land.

Remove the Block Capacity Allotments for Unitil Service Territory.

Unitil is currently oversubscribed at this writing. A 5MW project precedes our 3MW project and other projects are waiting with complete applications but no fees yet paid. The municipalities of Fitchburg, Ashby, Lunenburg and Townsend will be shut out of the

SMART program before it is promulgated by DOER. Just because the landmass of these towns is less populated than other utility service territories does not mean the taxpayers, landowners, business owners and municipal governments should not share in the SMART energy economy.

While we understand the methodology used to apportion block capacity allotments, in the Unitil territory, such methodology unfairly penalizes a less affluent, less populated area simply because it is serviced by a smaller utility company.

Restraints on program size again bring to the forefront the issue surrounding sizing the solar program on a percentage of Massachusetts electricity consumption by 2030. Such a policy would open up a clearer path for jobs, career choices, utility Grid Modernization planning, IMAP capacity modeling with ISO-NE and opportunities for municipalities to participate.

20.09 Solar Program Administrator.

It has been reported that DOER is considering pushing the administration to the utilities. Program administration is a policy management function, not a strict tariff responsibility. Appealing decisions of a third-party administrator to DOER will be easier than appealing decisions through the utilities. Please maintain the third-party administrator role, as the MassACA process has worked well and gives confidence to financing entities that there exists an independent structure managing policy compliance.

20.08 Calculation of Incentive Payments for Solar Tariff Generation Units.

2. Alternative On-Bill Credit Generation Unit.

If the On-Bill Credit Generation is handled much like the utility on-bill invoicing of a competitive supply line item on a customer’s bill, we understand that portion; we assume the payment of that line item to the competitive supplier is handled like any accounts payable to be paid in thirty days. Is our assumption correct? What are the mechanics of

this system with community and low-income solar customers? Is it simply filing a SMART Schedule Z? What does the enrollment process look like, and what is the handoff interface with utility?

Crossing ISO Zones Within A Holding Company.

Taxpayers in Boston and the urban core surrounding Boston should have equal access to solar generation. There is not enough suitable landmass within Boston and the surrounding Rte.128 belt that is capable of servicing this electrical consumption load.

Eversource customers in Boston should have access to solar generation located in WMECO territory in western Massachusetts. While there may be barriers in pricing, these should be overcome within the Grid Mod, utility tariff, and SMART proceedings.

We appreciate the ability to make comment on this important solar program.

Best Regards,

 

Doug Pope

President