Massachusetts
Renewable Energy Certificates (RECs) and Solar Renewable Energy Certificates (SRECs I and SRECS II)
Revised- January 27 , 2014
Preface
This is our eighth version of this report since 2010. RECS and SRECS policy and values are changing. There is
at present a market oversupply of Massachusetts SRECs I . The new SRECS II program beginning possibly in April will
be more balanced. Formerly all Commonwealth Solar eligible installers were required to inform customers and prospects
of the Massachusetts RECS/SRECS incentives. That policy requirement has been abandoned by the state. We continue to
provide a thorough disclosure here and in our solar quotes.
This report is one of the most popular sections of our website. Thank you for your comments and
passing it on to your colleagues and friends interested in the PV production incentives in Massachusetts. We’ll start out
with a summary update for our frequent website guests. They should read the new program concept comments at the end
however and there is new information in several sections. For those un-familiar with the complexities of SRECS and
RECS , start with Basic Facts on page 5, and follow the end notes for important details:
Summary
We predict SRECS I will sell at $150- 250.00 on the open market through 2016 as supply/demand balance.
The July 2014 Clearinghouse Auction will fail and not be bailed out by DOER.
SRECS II will have these same values these next two years. In all likelihood new PV
systems coming on line after April 1, 2014 will produce SRECS II.
For our pre -2010 Customers: RECS will sell at $20-$30 each over the next two years but small system PV
owners of RECS will find few brokers interested because of transaction costs. Call us at 413 743 -0152 for the
current list of possible brokers.
MA SRECs I & II



January 2014
SREC I Prices are ~$230.00 on the spot market this past week.
Surplus of SRECs I will continue in 2014 and 2015 .
Small PV systems installed after Dec 31, 2013 may still be SREC I eligible producers:
If a new PV project is completed prior to the start of the SREC II program expected to begin ~ April 1,
2014
The July 2013 Clearinghouse Auction failed to clear.
 Many PV owners deposited SRECS in the Auction because prices were in the $180.00 range in
June 2013 on the open market.
 Only 3 of 38,363 SRECS at $285.00 were purchased by utilities from the auction so it did
not clear.
 The Department of Energy Resources (DOER) stepped in to save the Auction and offered
to purchase deposited SRECS I at $285.00 each . Owners of 36,437 SRECS I took them
up on the offer. DOER spent $10,384,545.00 of their discretionary funds* but cautioned
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SREC owners to not expect a bail –out like this in future auctions. * DOER had $78
million in Alternative Compliance Payments (ACP) from utilities and electricity suppliers
who could not purchase enough RECS to meet their 2011 Renewable Portfolio Standard
(RPS). Predictions are that 2012 ACP funds available to DOER will be substantially less.

SRECS II. The rapid build out of Solar PV capacity in state since 2010 had exhausted the
original SRECS 1 carve out of 400 Megawatts (MW) within the RPS so an emergency
amendment of the RPS regulation occurred this past Fall to provide a transition cushion.
It is expected that with the cushion the original carve out will have expanded to 600 MW.
Governor Patrick has set a goal of 1600 MW of PV capacity by the year 2020 . The
establishment of SRECS II through another amendment of the RPS regulation is in the
works. This additional carve out will amount to between 1000 and 1200 Megawatts of PV
capacity eligible for a ten year program. DOER predicts this will allow 100-120 MW of new
capacity to come on line each year.

This table indicates the SRECS II incentive values announced on December 13th 2013
Reducing Incentive Value Over Time
Year
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
6
Auction
Price Bid
300
300
300
285
271
257
244
232
221
210
199
$/MWh
Auction
Price After
5% Fee
285
285
285
271
257
244
232
221
210
199
189
ACP Rate
375
375
350
350
350
333
316
300
285
271
257
Auction Price and
ACP Rate Schedules
No change from prior
Stakeholder Meetings
Values are included in
regulation
Values announced by DOER each year to
maintain 10-year forward schedule.
Creating A Cleaner Energy Future For the Commonwealth
The SRECS II Auction values are the same as for SRECS I for the next three years then steadily
decline. The program has a ten year forward schedule so say your PV system comes on line in 2016 your
last SREC II eligible year will be 2026. The ACP rate is much lower than for SRECS I ( see the next
chart). The ACP rate is the price an electricity supplier or utility must pay if it cannot meet its RPS
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obligation with SRECS II purchased from PV systems. Ideally the market price for an SREC II will be
less than the ACP rate and more than the auction rate.
To work to expand PV capacity in the state , the SRECS II program however is absolutely dependent on
an increase in the Net Metering Cap which regulates how much distributed generation like PV utilities
have to accept on the grid. That too will be before the legislature and Executive Branch soon.
SRECS I Forward Solar Carve-Out ACP Rate Schedule
Compliance
Year
ACP Rate per MWh
2013
$550
2014
$523
2015
$496
2016
$472
2017
$448
2018
$426
2019
$404
2020
$384
2021
$365
2022
$347
2023
$330
2024 and
after
added no later than January 31, 2014 (and
annually thereafter) following stakeholder
review
Note again that the auction bid rate for SRECS I is $300.00 each through 2023 and ideally the
market rate for SRECS I should be above that but below the ACP rate set by the regulation. In reality
the market rates for SRECS I have tended below the auction rate in 2012 and 2013. This is predicted to
change as supply meets demand in 2016 so SRECS I holders are expecting their value to be ~ $400. each
in the year 2017 when their ACP rate is $448.00 each . Compare the auction/ ACP split for the year 2017
for SRECS II : $285.00 each is the auction bid rate but the ACP rate is $350.00 each.
The incentive policy of SRECS I and SRECS II is to increase PV capacity in state. People who
dawdled and did not get in on SRECS I in 2010 through 2013 will earn a lower production incentive from
SRECS II in 2014 but still a quite generous incentive. It’s a different story for those who installed PV
systems prior to 2010.
While all PV systems constructed after January 1st 1998 fall within the “ Class I” category of the RPS,
PV systems installed prior to 2010 are not eligible for the SRECS I or SRECS II “carve out “
production incentive. They are only eligible to sell their production attributes as RECS. The table on the
next page will be updated by DOER at the end of this month . It shows the ACP value of RECS for the
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year 2013 at $65.27 each, considerably lower than the ACP value for SRECS I at $550.00 each for 2013
and the presumed ACP value of $375.00 each for SRECS II in 2014.
The following is directly from the DOER Website:
“DOER must publish each Compliance Year's adjusted rate for ACPs by January 31 of that Compliance Year
(per the RPS/APS regulations). The ACP Rate is equal to the previous year's ACP Rate adjusted up or down
according to the previous year's Consumer Price Index (CPI). ACP Rate of Next Compliance Year = (ACP Rate
of current Compliance Year) x (CPI of current Compliance Year / CPI of previous Compliance Year)
Compliance
Year
2013
2012
2011
2010
2009
2008
2007
2006
2005
2004
2003
2002
CPI
245.698
240.997
233.868
229.343
229.306
220.512
215.0
207.5
200.2
193.5
188.2
RPS Class I RPS Class I Solar
RPS Class II
ACP Rate Carve-out ACP Renewable Generation
Rate
ACP Rate
$65.27
$550
$26.79
$64.02
$550
$26.28
$62.13
$550
$25.50
$60.93
$600
$25.00
$60.92
$25.00
$58.58
$57.12
$55.13
$53.19
$51.41
$50.00
N/A
RPS Class II
Waste Energy
ACP Rate
$10.72
$10.51
$10.20
$10.00
$10.00
APS
ACP
Rate
$21.43
$21.02
$20.40
$20.00
$20.00
For a complete discussion of the various classes of RPS compliant generation see:
http://www.mass.gov/eea/docs/doer/rps-aps/225-cmr-14-00-062813-clean.pdf
Summary ( repeated)
We predict SRECS I will sell at $150- 250.00 on the open market through 2016 as supply/demand balance.
The July 2014 Clearinghouse Auction will fail and not be bailed out by DOER.
SRECS II will have these same values these next two years.
RECS will sell at $20-30.00 each over the next two years
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Basic Facts
RECs & SRECs use the same metric as electricity, a MWh (megawatt hour). 1,000 kilowatt hours ( kWhs) equals
1 MWh or slightly less than the average yearly output of a 1 kilowatt (kW) photovoltaic system in our region1 Endnotes .
Generally, a Massachusetts SREC can only be produced by a PV system on line after Jan 1, 2010. RECS are less
valuable and result from various attribute defined technologies : wind, low impact hydro , biomass and from any solar
PV system installed prior to 2010 but generally no earlier than Jan.1st 19982. Other solar devices eg. for hot water, air
heating or cooking etc. are ineligible.
Traded as if they were real electricity, measured as a MWh, a REC or SREC represents the associated renewable
energy ” generation attribute” separated from the energy. A Generation Attribute is defined in Massachusetts 225
CMR-14 as “ a non-price characteristic of the electrical energy output of a Generation Unit including, but not limited to,
the Unit’s fuel type, emissions, vintage, and Renewable Portfolio Standard eligibility. The C stands for Certificate once
the attribute is sold although Credit is commonly used to mean the attribute or the official certificate. There is a market for
these certificates of renewable generation goodness managed by the New England Power Pool Generational Information
System (NE-GIS or NEPOOL -GIS) . Utilities and electricity suppliers must meet a state regulated Renewable Portfolio
Standard (RPS) . RPS compliance allows their purchase of RECs or SRECS in lieu of real renewable electricity. While
utilities are the primary buyers of RECs and SRECs, there are also voluntary purchasers who wish to lighten their carbon
imprint. Aggregators , SREC/REC traders and brokers, (twenty -four are listed by the state as eligible brokers ) sell
these certificates on behalf of PV system owners.
The actual energy from a PV system measured on the solar kWh meter at the site has a value as ‘net metered”
generation reducing your electric bill3. This is the primary value, a different financial benefit from tradable RECS or
SRECS.
Once a PV system owner sells the RECS or SRECS , the energy from their PV system is just as “dirty”or
unsustainable as the conventional electricity mix. This may surprise some people because it is not widely known but see
page 34 example 5 in the Federal Trade Commissions’ “ Green Guides” :
http://www.ftc.gov/sites/default/files/greenguides.pdf
Reasons for the SRECS Program
Because Photovoltaic or solar electricity is clean, costly and new, incentives have been created for its adoption. 4
Massachusetts Rebate amounts have fallen since 2002 and stayed flat since 2010. RECs for PV were popularized in
2003. Their value consistently diminished. A special category of Massachusetts Solar RECs, SRECs was carved out of
the full RECS quota to encourage new PV capacity construction. It went into effect in January 2010. The Department of
Energy Resources(DOER) has developed a program which prompts a floor value for SRECs for a period that has been
extended to 2024 and may go longer. The Massachusetts SRECs incentive along with the federal 30% tax credit for
investing in PV makes for an attractive return and thus to increased solar capacity in the state.
Look to the next revision of this report or go to:
http://www.mass.gov/eea/energy-utilities-clean-tech/renewable-energy/solar/rps-solar-carve-out/
for the latest policy pronouncements and program updates. There are many stakeholders in this policy to promote clean
energy in Massachusetts; their conflicting interests contribute to its complexity. Our views here and in comments to the
DOER regulatory process ( at the end of this report) represent the perspective of early adopters and small PV system
owners
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SREC Eligibility Requirements & Market History
1. Only PV systems which come on-line after 2010 ( with exceptions2) and until the program cap of 400 MW is
reached are eligible for SRECs. As of this writing , January , 2014, well over 850 MW of PV is planned with
~ 350 MW actually on line producing SRECS in MA. Massachusetts is one of the globe’s hottest markets for
solar investors because of SRECS and has attracted hundreds of firms. Large scale solar installations have
already staked out the majority of SRECS available.
2. The number of SRECs utilities should purchase to comply with the Solar portion of their RPS (Renewable
Portfolio Standard) is adjusted upward each year. In 2014 it is certain that the utilities will enjoy a buyers
market. There will be a glut of over 30,000 up to 75,000 SRECS above the RPS requirement. DOER can adjust
the SRECS requirement for subsequent years. Again once total capacity reaches 400 -600 MW then new PV
capacity will be eligible to sell attributes as SRECS II. New program regulations will be formulated by March
31st 2014 for SRECS II. Owners must sell SRECS within a year of their creation with one exception5.
3.
If the utilities do not purchase SRECS to meet their annual RPS mandate then they are subject to pay an
Alternative Compliance Payment (ACP) which sets a ceiling price per SREC. In 2010 that amount was $600.00
per SREC. DOER has scaled the 2013 price at $550.00. Their current table extends the ACP rate . In the year
2023, the ceiling price is $330. for each SREC I and for SRECS II in 2023 $271. each is posited.
4.
SREC regulations attempt to set a floor price through a complex clearinghouse auction. As designed this
auction was to provide that SRECs would have a starting value of $285.00 ( actually $300.00 but there is a
$15.00 auction fee) The expectation was that owners would be able to sell their SRECs for more than $285.00
each on the spot market and DOER would not have to offer a clearing auction.
5.
Prior to and in March, 2012, SRECS sold at ~$500.- $550.on the spot market
In July 2012 they sold for $271.
No one deposited SRECS in the auction clearinghouse in July of 2012..
In October 2012 the average price dropped to ~$245. In June 2013 they dropped to $180. each
In July 2013 the auction failed and DOER bailed out the SRECS market at $285.00 each
In January 2014 SRECS sell for ~$230.00 each
6. Many people are asking why SRECS are selling below $285.00, the DOER floor price.
In July 2012 with spot prices already cut by half, no one chose the auction course. Holding them for
a better price in 2013, 2014 or 2015 was not seen as a wise course .One can deposit their SRECS in the July 2014
auction; DOER will attempt to get the full auction block purchased in three calls but there is no guarantee the price
of $285. will hold; a portion of the block deposited in the auction may not sell at all. Remainders get re- minted and
returned to their owners to sell in two to three subsequent years. These re-minted SRECS cannot be deposited in
future auctions. They must be sold on the spot market.
Reasons for the SRECS value drop:
 A glut of new PV capacity came on line in 2012 and 2013. More SRECS were ‘minted’ 6 than the utilities
needed to buy. Utilities however are allowed to buy more on the NE-GIS and bank up to 10% of their needs
for a given year. The glut will grow this year and continue.
 There is a bi lateral , long term, forward market for SRECS. Into this market solar developers have pre sold
MA SRECS from their projects to SREC aggregators and brokers even though their PV systems have not
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produced them yet. These “forward” SRECS sell now, we hear, for $150.00. These are complex deals with
future SRECS and assets functioning in loans and securities. Solar developers needing cash in a hurry also
explains this short selling in potential Massachusetts SRECS. Aggregators/brokers will need to sell these
large blocks of SRECS quickly which can cause steep discounting.
 Massachusetts utilities still have an option to build up to 200 MW of PV they own themselves and earn
SRECS on their production. 7
The Market Forward & SREC Price Projection
Massachusetts has better safe guards than New Jersey and Pennsylvania where SREC prices crashed
hurting many investors. The Clearinghouse Auction can extend the life of surplus SRECS. Regulators can alter
factors that will increase SREC demand slightly and legislation can make major changes to increase demand or
SREC value. Generally for MA SRECS the small system PV owner is at the mercy of market forces dominated
by large PV system owners and their aggregators.
RECS
For small and large PV system owners the RECS incentive was glowingly touted in 2003 as a long term
generous production incentive. Pricing began at $50.00 per REC , enthusiasts predicted they would easily reach
$180.00 per REC in a few years. It did not happen. Other interests succeeded in widening the energy
technologies eligible to generate RECS . RPS compliance could be purchased from generators in other states.
$30.00 per REC ( $0.03 per kWh) was the average price 2005- 2012. Small producers could not renew contracts
with aggregators in 2007 and their RECS went unsold and effectively expired. It is not widely
understood that the SRECS quota is a percentage of the original RECS full quota. SRECS are a “ carve out”
program; as a result the RECS program saw lessened demand.
By 2012 however due to the steadily increasing percentage of RECS mandated by the MA RPS and the
institution of RPS mechanisms in other states, there was an undersupply, so MA utilities made ACP payments at
~ $62.00 (per REC equivalent) in 2012. Unlike SRECS which can gain an extended life through the DOER
Clearinghouse auction, RECS absolutely need to be sold within a year of being produced but it is very difficult
for small PV system owners to find a broker. They’d rather deal in SRECS and eschew RECS unless they come in
very large quantities.
How can I sell my SRECS or RECS ?
You need to sell your attributes through an aggregator /broker. It is not cost effective for small PV system
owners to trade on the NEPOOL –GIS.
DOER has compiled a list of aggregator/brokers you can contact for detailed offers.
http://www.mass.gov/eea/energy-utilities-clean-tech/renewable-energy/solar/rps-solar-carve-out/
If you cannot download the list in a readable form please call or e-mail BPVS for a copy.
To enable the sale of SRECS/RECS your PV system production must be reported monthly to the
Massachusetts Clean Energy Center Production Tracking System (PTS). When BPVS installs your PV system we
make sure it is registered on the PTS for you. We’ll present options to manually report or to provide automatic
reporting equipment installed with your PV system. Automatic reporting is required if your PV system is over 10
kW in capacity. With either choice BPVS installs a revenue –grade, new ( not reconditioned) solar kWh meter
identical to the best meters utilities use.
Manual reporters will receive a username and a password from the PTS administrator. Each month the PTS
system sends you email notices to enter your production tally from the solar kWh meter. You’ll receive multiple
notices and have a ten day window to access your PV system page on the PTS and enter the number of solar
kWhs. If you ignore notices or forget to make the entry you can catch up the following month. We do not advise
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you skip months often however because the PTS system is wary of production entries that appear high and will
challenge you for an explanation.
Automatic reporting equipment uses a datalogger ( Data Acquisition System or DAS) interfaced to the solar
kWh meter and hooked into your computer network or to direct internet access. There are many bells and whistles
with automatic reporting equipment and brands and they range in cost from a few hundred dollars to several
thousand. The key part of any DAS is the PTS reporting service. Most customers choose a ten year service plan;
the device manufacturer is designated as your PTS reporting representative and is obligated to update your PTS
tally each month for ten years.
If you’re only eligible to sell RECS from your PV system there are conflicting rules from the MASSCEC –
PTS barring manual reporting 8. If you do not have high speed internet or cell phone access at your site ( you are
not alone in Western Mass) and/or if you simply prefer not to use email, BPVS can still provide PTS reporting
services for you. More about the PTS and its’ relation to SRECS or RECS may be found at :
http://www.masscec.com/index.cfm/cd/fap/cdid/11539/pid/11151
The PV system usually needs at least one month’s tally before it can be registered on the PTS. If you choose
to sell your RECs /SRECs to an aggregator you will give them permission to access your production tally on the
PTS. A degree of fraud protection is part of the PTS software; it can identify outliers and request clarification if
you report more production than is possible or likely given the weather and the tally from comparable PV systems
in any given month. There is also a degree of quality control, the PTS alerts you if your PV system is producing
below par. Whether you manually report your tally each month to the PTS or it is automatically reported, you
too have access to the PTS production tally page on their website. Massachusetts should be proud of the PTS.
The aggregator will submit to NEPOOL –GIS and DOER a statement of qualification for your PV system9.
All of the technical details you and they need for this document are included in our contract and system design
documentation however it’s often the case that an aggregator will send you a form then ask us to fill in the
technical sections for you; we’re happy to do this at any time at no charge. Sometimes our customers switch
aggregators after a system has been installed. Our documentation help is still a free service.
At this point and after your solar system has made at least 1000 kWh or 1 MWh you’re ready to sell SRECS
or RECS. The aggregator you select will have a variety of “plans” you can option to sell the SRECS or RECS
and how you will be paid. Unfortunately, neither the DOER nor the Massachusetts Clean Energy Center nor the
Office of Consumer Affairs and Business Regulation present any detailed guidance on these important plan
variables.
At BPVS we know that it is a conflict of interest for us to recommend any aggregator/broker. advise you on
their offers or be both an aggregator and design /installation firm . Please read on to understand our policy.
BPVS POLICY & DISCLOSURES on RECS/SRECS
1.
Our contracts for PV installation, service or repair do not include a clause or clauses with conditionals or
any vague language that takes ownership of SRECS, SRECS II or RECS from you , or takes implied
equivalents such as ‘Carbon Credits’ , ‘Emissions Credits’ , ‘Pollution Offsets’, ‘Clean Energy Attributes’,
‘Environmental Financial Incentives’ or ‘ Green Tags’.
2.
BPVS cannot recommend any particular firm or aggregators/broker to you. It is common practice for PV
installation firms to represent aggregator/broker firms, and receive commissions from them. Neither the
installer nor the aggregator/broker is required to disclose such relationships. Some PV firms are also
aggregators. 10 When shopping for a PV system if the PV installation firm, coordinating service firm or
leasing salesperson does not disclose your eligibility for RECs or SRECs or suggests that they will “take care”
of that for you...be careful. We supply you with the full list of MA eligible aggregator /broker firms to select
one for yourself.
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3.
It is not that hard to research offers yourself; the sign up process with an aggregator is easy. Typically our
new PV customers have been referred to us by a past customer who can provide you guidance.
4.
BPVS supplies new ( not reconditioned) solar kWh meters identical to the best meters utilities use; our
meters are digital, that is, easy to read and supplied with tamper indicating seals, unbroken and 0 kWh
registered at start. We register the solar kWh meter serial number in your file and add a tamper indicating seal
to the meter base hasp. Automatic DAS equipment we supply is from a third party provider unassociated with
us or an aggregator/broker. Should the DOER, or the Department of Public Utilities ever challenge the meter
readings or DAS reports from your site we’re happy to verify the equipment installed is revenue grade.
5.
You do not have to sell the SRECS/RECS from your PV system. Not selling them means you have retained
the clean energy benefits or “generation attribute” with the electricity. The BPVS website includes a table to
calculate deferred emissions from your personal or “on site” solar energy use.
6.
Aggregator/Brokers typically charge a fee ranging from 2% to 10% of the sale price they get for your
SRECS/RECS. For small PV systems the aggregator bundles their SRECS with those of others to trade in large
blocks. Consult your tax advisor; generally proceeds to you from SRECS/RECS sales are considered taxable
income.
7. This report includes values for SRECS and RECS based on public information at the time of the report date.
BPVS provides this price information, projections and analysis in a conservative light as a service to our
customers assessing risk. Some solar sales pitches present SRECS and SRECS II values at their highest
possible price in their financial anmalysis. RECS history, SRECS recent history causes us to refrain from such
charming optimism for this complex market.
SRECs/RECS Pricing Conclusion
Despite the unevenness of RECS and SRECS values in Massachusetts the financial benefit of owning a PV system is
still compelling. Our quotes analyze this for you at uniform present worth.
Policies will continue to change, if our civilization is serious then incentives for solar should improve.
This is why forfeiting ownership of the “green attributes” or “environmental financial incentives” etc. or settling for a
low price for the duration of a ten or more frequently 20 year contact is not prudent.
Endnotes:
1. Between 11:30AM and 12:30PM, on a bright sunny day a 1 kW (kilowatt) system will generate 1,000 watthours or 1
kWh(kilowatt hour). If you leave a 100 watt light bulb on for ten hours it will use 1 kWh. The average New England
home without an electric hot water heater uses 650 kWhs per month. In twelve months it will use 7,800 kWhs, or 7.8
MWhs and need a 7 kW PV system to offset its’ utility purchases of electricity.
2. Certain PV systems which were installed in 2008 & 2009 may be eligible if those system owners did not receive
rebates or grants from the Commonwealth Solar I program or its predecessors funded by the Massachusetts Renewable
Energy Trust (MRET) or received a waiver from DOER. Pre -2008 installed photovoltaic generation systems are not
eligible for the SRECS program. All post 1997 PV systems are still eligible to produce and trade their RECs as Class I
RECS . Solar PV systems installed before January , 1998 are not retroactively included by RPS legislated incentives for
Class I RECS even though they have been and are generating solar kWh on the grid. With DOER special permission they
can qualify to sell attributes as Class II RECS. Class II RECS are even less valuable . The Classifications of RECS by
vintage and technology would take another essay to discuss.
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The Electricity Restructuring Act of 1997 established the Renewable Portfolio Standard , (RPS) with annually increasing
goals for cleaner generation on the grid from regulated utilities. Graduated in price for the cleanliness of the renewable
energy source, utilities and suppliers purchase these from a free market at prices , more often than not, well below the
ceiling or penalty price.
3
Net Metering
Keep in mind that the real solar electricity is used within your building as it is generated and this defers you buying its
equivalent from the utility. Sometimes, the power generated from the PV system can exceed your needs and the extra is
automatically exported to the grid. Since Jan. 1st 2010 every exported kWh you send to the utility grid is compensated at
almost the same retail rate you pay for electricity. Formerly, exported power was compensated at the utilities wholesale
rate approx. $0.03-$0.06 per kWh. Now in MA the value of your exported kWh is at the retail rate (approx. $0.126 $0.145 per kWh) minus two small system benefit charges per kWh of ~ $0.000500 to the Massachusetts Renewable
Energy Trust administered by the Massachusetts Clean Energy Center of the Department of Energy Resources & ~
$0.002500 to the Energy Conservation fund administered by the various utilities. The compensation rate is changing as
utilities’ de-couple’ electricity pricing and temporary charges ( such as Storm recovery surcharges) appear and disappear.
Consider $0.125 a safe export kWh value for 2014.
As part of a PV interconnection application and agreement with the utility, we also help you fill out their Schedule Z .
This form designates how exported kWhs are credited; most of our customers carry the credit over from the sunny
summer months and bank them to reduce their winter month’s electric bills, others apply their credits to separate utility
accounts.
4 “Costly ” as in relative economic value under present regulations. The externalities not valued under present law are
calculable through categories as varied as reduced health care costs, environmental clean up and defense appropriations
and more. Properly analyzed, PV generation is a bargain. “New” as in energy market acceptance. Terrestrial
Photovoltaic installations have a long history in Massachusetts going back to the 1970s.
5.
See –MA - 225 CMR 14.00 RENEWABLE ENERGY PORTFOLIO STANDARD CLASS 1 ; there is an exception;
you can deposit attributes in the DOER Solar Credit Clearinghouse Auction and depending on how the auction clears or
fails to clear they gain an extended life to sell in up to three subsequent years.
6.
Minting: The process of depositing Attributes on the NEEPOOL GIS to turn them into immediately tradable
SRECS. Re- minting: Depositing attributes in the DOER Clearinghouse Auction to create extended life SRECS.
7.
A provision added very late to the Green Communities Act of 2008 allowed utilities to own and build up to 200 MW of
PV generation , financed through all ratepayers. Utility owned PV capacity counts towards SRECS compliance . Some
is built ; utilities can exercise their capacity build out plans quickly and are actively petitioning to accelerate multi MW
installations. Utility ratepayers are charged by their utility for project capital costs. Regulators have set provisions for the
utilities to confer benefits of these installations back to their customers.
8. MASSCEC- PTS has reported that pre -2010 PV systems which now want to qualify to sell RECS and report to the
PTS monthly must have automatic reporting even if their PV system is under 10 kW in capacity. BPVS is trying to have
this policy changed as it is a costly burden for small PV owners, some of whom do not have reliable internet access. Pre
2010 PV owners who wish to increase their PV capacity now face unnecessary complications. Expansion capacity has to
be separately metered so REC and SREC tallies are isolated which involves greater expense in power conditioning units,
switchgear and solar kWh reporting.
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9.DOER publishes on its website a list of all SREC eligible PV systems copying information from this statement of
qualification that identifies your site by name, the aggregator representing you, system costs and technical details.
10. Most Solar Lease or Power Purchase Agreement firms are aggregators/brokers as are some solar contractors.
BPVS Comments to DOER in 2013 on SRECS I and II
The Concept of RECS /SRECS and Attributes ( Abridged from BPVS comments letter 3/1/2013 to DOER)
.. Separating green attributes from the energy of solar electricity was bound to be messy but the model is now in place
in several states along with Renewable Portfolio Standards (RPS) . It has to evolve to be replaced.
An enduring principle in formal logic is the ‘attribute’ of a thing lags behind it. Just a shadow of ‘reality’, it is not
supposed to have a life of it’s own. When it does, paradoxes multiply. The Massachusetts Regulation 225 CMR 14.00
defines a “ Generation Attribute” as “ A non-price characteristic of the electrical energy output of a Generation Unit
including, but not limited to, the Units fuel type, emissions, vintage and RPS eligibility.” We have to assume that
something without a price value will form the basis of a market in which it is monetized and becomes an instrument in a
specialized financial sector. Attribute is correctly denoted to mean characteristic. Property would be another synonym.
A part of the definition is the word output meaning that it can be measured as if it was electricity. The singular, attribute
is not limited in the definition; the plural attributes in the market and in the text of the regulation is used interchangeably
for: qualities of the generation and, quantity of the price- added, megawatt hours of the attributes. This begs the
question: How many attributes can dance on the head of a NEPOOL –GIS certificate?
It is tempting to digress and compare this model with the excesses of Scholasticism and then discuss the financial
similarity of RECS/SRECS to medieval indulgences. Marrying the obligation of environmental healing to a volatile
speculative market is also not a match made in heaven. The win –win deal is the signature utopian concept of our times.
This attribute program is not immune to that background belief; in the foreground are some disenchanting facts.
PV systems produce their electricity and thus attribute(s) daily. Whether RECS or SRECS eligible their energy is
equal. Age discrimination, that is, age of the PV installation makes a REC as much as ten times less valuable than a
SREC. This duality was excused by stating that pre -2010 PV installations received more generous rebates. The
SRECS higher value is supposed to make up for that. In fact pre-2010 PV costs were dearer, equipment costs have come
down since. Many owners were not eligible for the present 30% federal tax credit favor in 2008. Policymakers waived
the SRECS eligibility calendar for some PV systems built with federal ARRAS grants in 2008 and 2009 so long as that
funding was less than 67% of the PV systems’ total cost. Very, very few of the pre 2010 or pre- 2008 nearly fourteen
megawatts of PV systems installed in Massachusetts received more than a 40% subsidy. The SRECS quota in
Massachusetts is a ‘carve- out’ from the original RECS quota. Thus the total renewable energy in MWhs required of
Massachusetts electricity suppliers did not increase, only the cost utilities pass on to all ratepayers ratcheted up, albeit,
slightly for any account holder’s individual bill.
Other consequences were more serious. RECS having lost value, aggregators/brokers abandoned serving small pre
2010 PV system owners. Their transaction costs were too high to handle RECS selling for less than $30.00. The
introduction of SRECS meant that value was subtracted from RECS. What’s worse, pre 2010 PV system owners who
planned to add increments of new capacity as they could afford it, were faced with added costs, in some instances to
duplicate power conditioning equipment, but in all cases of new array capacity, to install a separate solar kWh meter
circuit. Further reporting and transaction costs to assure SRECS eligibility have been their burden too. Imagine
explaining this policy change , consider how absurd it is for a PV owner to have two identical solar kWh meters in their
basement, the pre -2010 one pays $0.03 per kWh ,the new one pays as much as $0.55 per kWh. One meter was sufficient
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to measure the clean electricity generating any day. Vintage, a characteristic the regulation reserves for some non -PV
generation units became a determining price attribute of the generation attribute for PV.
What we understand by “attributes of PV renewable energy” are, environmental, societal and technical excellencies
of the same order. One important sub set is deferred kilograms of CO2, NoX and SoX , grams of mercury and a host of
other heavy metals and particulates affecting all organisms, disrupting climate progressively. Real price values
calculated for human health, local jobs, and grid reliability to name just a few are inherent. The emissions index from
conventional grid electricity did not get suddenly worse in 2010 when SRECS were introduced nor did it get much better
in the Summer of 2012 when their value crashed. Maybe we mean that clean energy goodness is not part of the attribute
sold at all. Its’ either a valueless, fleeting appearance of no urgency or the opposite; it’s one of enduring usefulness..
Green status value and bragging rights , many people who’ve sold RECS/SRECS believe its’ a win –win deal wherein
they can claim the environmental virtues of their PV production and the money.
The metric of a megawatt hour for the attribute however is the same. Whatever is being sold, when Massachusetts
policy changes, history proves the market complexion for PV will frown on the old and smile on the new. The lesson to
RECS eligible PV early adopters ( pre 1998 PV pioneers fare even worse) and then to SRECS eligible PV owners and
leasers and power purchase parties and those contemplating PV development since the price crash in 2012 is that
buyers’ regret or wariness is not only one of missteps in market timing but trusting policy changes to not be disruptive .
This polemic is not questioning the sincerity of policy intent or the earnestness of policymakers. Contrition is due of
all stakeholders since the late 1990s’ for not thinking of alternate ways to reward PV production. We need to recognize
that the renewable generation technology has within itself, the genome, if you will, for it’s ‘attribute(s)’ consistent
market value. PV succeeds as no other in that appraisal but...
225 CMR 14.00 has to evolve to be progressive , here are suggestions to signal market consistency through those
changes:
 Subsume all ineligible MA PV capacity since 1970 under the SREC Classification effective Jan 1, 2013.
 Apply any upward combination of adjustments in the SRECS Cap tally( from capacity factor review or use of
ACP funds in market support) to accommodate early adopter inclusion first. Honor the trailblazers in policy
pronouncements.
 Set a goal to differentiate PV production incentives tiered to Interconnection Capacity class by the end of the
SRECS term.
 The first step, by 2015 require all utility owned net meters to register and utilities to record , export solar kWh
from interconnection sites 25 kW or less.
 Begin to allow in 2014 , customers who already have this regimen of metering from their utility to receive a
positive solar bonus credit on their billing equal to deferred kWh price x 2 + ½ the kWh value of the net
metering recovery surcharge for any site exported solar kWh in addition to the SREC for the total solar kWh
tally. Follow up in 2015 to extend the bonus to all utility PV customers in this capacity class.
 Require utilities to compensate by check upon request of any PV owner in this capacity class for carry over billing
credits that exceed $500.00.
 This could be called the Transitional Production Incentive, that is, the transition to re-uniting the energy and the
attribute(s). It will foster conservation during PV peak production hours and seasons and relief for some PV
Host accounts. Obviously some reckoning should prohibit lessees and PPA payers from having to hand over this
incentive to the PV equipment owner.
 These changes to increase the incentive in this class during the SRECS term should be funded by a combination
of ACP credits and the rate base.
 Beginning in 2023 a utility direct bonus credit will be the single state incentive for PV generation
( exports and used on site kWh ) in this class representing the energy and its’ attribute(s).
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
Other PV Interconnection Capacity Classes need a different schedule and program to transition to a unified
incentive formulated as a bonus credit and may welcome valuation consistency.
BPVS Comments to DOER at the June 7th 2013 Stakeholders meeting at the Statehouse:
Michael Judge, RPS Program Manager
Department of Energy Resources
100 Cambridge Street, Suite 1020
Boston , MA 02114
BPVS,Berkshire Photovoltaic Services
46 Howland Avenue
Adams, Ma 01220
Christopher Derby Kilfoyle
June 7, 2013
Dear Mr. Judge,
Thank you for the opportunity to make these comments at the Massachusetts Solar Policy Stakeholders’ meeting
today for consideration of an Emergency Regulation or change pertaining to 225 CMR- 14.00 and on policy
considerations for the Governors expanded goal for achieving 1600 MW of PV capacity in the Commonwealth by the
year 2020.
On behalf of BPVS and our PV customers the broad framework for an emergency regulation and review of the
SRECS oversubscription crisis expressed in the solar industry letter to Commissioner Sylvia of June 6, 2013 is supported
and I co- signed this letter with the same deep concerns of many solar colleagues for a prompt and fair remedy to
assure authentically ready PV projects are eligible for the initial SRECS program capacity.
In particular we consider the 60 MW set aside for small systems as noted in Section C of the updated, May 22, 2013,
RPS Solar Carve-Out Assurance of Qualification Guideline released by DOER must be maintained , if not expanded in
the Emergency regulation pertaining to 225 CMR 14.00. Among many PV systems of this category in progress of
installation and permitting by my firm, there are farm projects in Berkshire , Hampden, Hampshire, and Franklin counties
which have been planned for as long as four years. These farm projects leverage grant funding from competitive USDA
REAP and MDAR Ag Energy grant programs. Farm applicants have typically secured personal funds and bridge loans to
demonstrate in application documentation their certain financial viability to achieve project completion and the farmers’
ownership of the PV capacity. Applications have been accepted by these agencies under the May 30th 2013 and March
30th 2013 deadlines ( many just made it) and are under review through the summer with awards expected in
September. The strict requirements of these farm renewable energy programs include: modeling the SRECS production
incentive as part of financial payback and technical design performance, proof of site control , jurisdictional approvals ,
environmental approvals and review and associated site maps , engineering studies, utility notification, construction
drawings and wire diagrams. REAP applications are often at least 125 pages long. Several of the family farms we work
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with have been putting aside savings dedicated for proving eligibility for the program for many years. Several have also,
with great effort, over the last few months worked with local banks to secure the promise of bridge loans to assure
program application compliance. None of these farms have either a secured SQA or one pending and that is the case
also for other small PV systems in process through our firm. The expectation was there was enough time this summer to
meet the RPS Solar Carve-Out Assurance of Qualification Guidelines for these small systems. Thus we hope DOER will
pay special consideration to projects which meet the set aside, small capacity, requirement and exceed all and any
criteria for readiness to proceed to construction within the year.
The Patrick administration, the legislature and DOER and MASSCEC deserve the highest praise for their efforts to
support renewables in a fiscally balanced and fair process. Massachusetts leads the nation in policy to accelerate
environmental healing. In no small way the global technical excellence of Photovoltaics depends on the innovations
nurtured and demonstrated here since the 1970s by early adopters including our private and public academic
institutions, PV component manufacturers and integration firms, our utility companies and our citizens. The initial solar
carve out RPS program in many ways penalized some of these early adopter PV capacity owners. These inequities have
been addressed in detail in my earlier comments on this process. Going forward lets re-dress this unfortunate policy
omission by extending eligibility for a new production incentive to this group which represents a relatively small ( ~ 14
MW) but historically seminal increment of capacity still producing daily emission deferral benefits. The confidence of
future investors in Massachusetts solar capacity will be enhanced by a policy that says we’ve left no trailblazers behind.
The post 400 MW program policy should honor PV ownership by Massachusetts ratepayers. The community
supported solar power plant model and small system loan program models have not received the policy emphasis they
deserve in recent years. This vacuum has led to opportunistic lease and ppa finance schemes gaining ascendancy in the
municipal and residential markets. Objective financial guidance and education from state agencies needs to be
deployed quickly so towns and citizens can understand the benefits of ownership and the pitfalls of allowing long term
financial returns flowing to third party , non rate paying , often out of state investors cashing in on our progressive
programs.
Lets simplify access to a new production incentive for small systems at the very least so the ownership model can be
presented without excessive transaction costs for citizens and a reasonable return can be achieved from a consistent
factor per kWh ,one without the volatility only large investors can bear hedging. It’s also time to honor the primary
motive for small system ownership, environmental responsibility. The charade of separating attributes from electrons
or btus for that matter does not fit the sensibility we need to initiate for the consciousness of successor generations in
this and the next century who will finalize the clean energy adaptation.
That adaptation also depends on professional solar installations. An important function of sustainable systems is
durability and safety. Along with an ambitious capacity goal by 2020 should be the establishment of a licensed solar
contractor category in Massachusetts.
Thank you again for this forum and listening to these policy suggestions.
Respectfully,
Christopher Derby Kilfoyle
In verbal reply DOER spokesperson Dwayne Breger courteously acknowledged “these good folks” meaning the
early adopters who have been shut out of the SRECS program and reiterated the DOER stance that they went
ahead with their PV investment based on “the economics of the time”. In follow up I pointed out the numerous
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changes and waivers DOER has made in the economics and eligibility policy since 2010 when the SRECS program
was initiated which have favored early and late- coming large scale PV investors. There was no response except
assent as applause from veteran PV experts in the room. We will persist in seeking a fair production incentive
policy as the SRECS II program regulations are debated this year through December of 2013.
Michael Judge
Department of Energy Resources
100 Cambridge Street, Suite 1020
Boston , MA 02114
Christopher Derby Kilfoyle
August 21, 2013
Re: Comments on the RPS Solar Carve Out II – Updated Proposed Design
Dear Mr. Judge,
Thank you for the opportunity to submit theses comments on the SRECS II program design detailed at the August 12,
2013 Stakeholders meeting. The Patrick administration and DOER should be pleased the original SRECS program has
met its goals and the citizens of the Commonwealth should be glad for their efforts in leading the nation with prudent
solar incentive policies.
These comments address the specific questions presented by Dr.Breger at the end of his presentation on
proposed policy changes for SRECS II.
Are incentive levels sufficient for project development ?
Possibly , if:
 The auction floor price for SRECS II and it’s annual clearing is guaranteed.
 The Federal 30% Tax Credit is renewed for Residential and Business owners.
 SREC Factors are not adjusted widely down or more than once yearly.
No ,since:
 Prospects are wary of the SRECS/RECS market; it is not bankable
 Commonwealth Solar Rebate for small systems ends.
Residential and non –profit owners cannot capture equal tax benefits businesses can.
PV owners who choose to retain generation attributes cannot use the SRECS incentive.

Program is too complicated to explain properly
Citizens are suspicious of the solar policy enterprise, it seems unduly complex on purpose.
The curious have seen a confusing range of presentations by government officials and industry.

SRECS factor adjustments, schedule of declines adds to cascading risks.

Increased costs for equipment and labor.
The economies of scale in manufacture are ready for higher efficiency cells, but global ‘over
scale” and cheaply made products lead to the low prices of today. Projects will see increased
costs based on market demand for reliability of equipment, durability of services and
PV workforce professionalism during the SRECS II term.
Suggested Solutions:
 Calter Bill passes firming the SREC floor or regulation firms the floor.
 Regulation requires incentive change upward in early 2017 if 30% federal tax credit declines or disappears.
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
Residential owners and those with moderate means or home value receive a higher incentive . Non Profits
receive a higher incentive.
 A Non- SREC incentive is created as an option . ( see Endnote)
Are there market sectors omitted in the non-managed, non-competitive group ?
 Community Shared Renewable PV projects meeting residential criteria, but in the aggregate exceeding 500 kW
at a site, should be exempt from the lower SREC factor for landfill/ brownfield, ground mount and
competitive bid solicitation sectors.
What Guidelines should DOER follow to modify SREC Factors?
 Is the SREC factor complication really necessary with a firm floor and declining ACP ?
 Could DOER simply note the potential need for the emergency regulation process as market or tax policy crises
erupt?
 If the factor adjustment lever is allowed to DOER, isn’t it inevitable that we’ll see multiple factors for sub sectors
than those posited? Despite the department’s sincere assurance of discretion and limited application of throttle
and brakes to the market there’ll be multiple hands on the steering wheel.
 If the factor is part of policy, please limit adjustments to once yearly.
SRECS Forward Minting
Forward minting of SRECS as a mechanism to encourage direct ownership of PV in the residential sector is a
laudable new policy initiative. Extending this incentive to Community Shared PV projects meeting residential criteria
recognizes the pent up demand among ratepayers with non - viable sites or limited means. Coupled to innovative, solar
specific, finance options for the ownership model, this aspect of the SRECS II program will have a significant economic
multiplier effect within the state. It will earn almost as much ratepayer respect for Massachusetts solar subsidies as the
non -SREC production incentive detailed in the endnotes of these comments. There are cautions to consider:
 Any discussion of this new policy must anticipate the backlash from residential participants in Commonwealth
Solar and earlier programs reliant on relatively modest rebates and from those who in recent years locked into long
term residential lease/ppa contracts with 3rd party ownership (TPO) providers. Their regret for acting too soon will
transfer into a marketplace perception that incentives do get more attractive over time.
 The discount of 10 year production, DOER may establish for this offer, presents a dilemma. The best solution is
to set the SREC forward minted value- factor at the same price for the duration of the SRECS II program or until the
30 % federal tax credit expires, whichever comes first. No matter which year a participant receives a commercial
operation date a consistent price will help prevent a land rush the first year(s) of the program.
 Based on a balance of the SRECS II ACP rate , the SRECS II auction floor rate and in recognition of the SRECS I
recent clearing auction, a price of $270.00 after fees is appropriate to spur development in this sector and mollify
criticism from SRECS I residential participants and ratepayers.
 It is not clear that DOER will act as the buyer of these SRECS although that is recommended to relieve the
consumer of complicated arbitraged offers from the private sector,. To ensure a level playing field DOER should
mandate a set price and maximum commission fee if the aggregator community is allowed to handle this forward
transaction. The option to owners for a three year shelf life is unnecessary with a set price.
 Prescribed, model contract language vetted against Massachusetts residential contractor and consumer
protection law must be included in all development and
installation contracts or separate loan agreements which offer financing on, or assignment of the future payment for
forward minted SRECS.
 Performance estimation and independent metering verification as currently required by the Commonwealth
Solar Program should be detailed in prescribed contract language and a DOER eligibility agreement. DOER should
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consider language assuring a pre- emptive waiver of penalties for the end of or reduced production performance of
the resource over the opt in term resulting from natural catastrophes or acts of God.
 DOER should prepare a disclosure statement in an eligibility agreement that fully describes the incentive and
legal requirements of the owner, any finance agent, and the installer/developer and require initialization of it
having been read.
. Forward Minting Incentive and 3rd Party Ownership Companies
TPO providers in the residential sector are in the business of equipment leasing and/or acting as a virtual utility. They
should not be beneficiaries of SREC forward minting. The Commonwealth Solar program has a defensible sound policy in
this regard. TPO residential sites were not eligible for moderate home value or moderate income adders.. The
substantial incentive, SRECS II, forward minting represents, dictates program requirements of all parties involved
without exceptions.
Arguments that the TPO provider could or would reduce the lease or ppa terms for the residential account owner to
partially or fully value the receipt of forward minted SRECS remain to be seen. This argument could be equally made by
TPO companies in the commercial, institutional, and government sectors for large systems to benefit their electricity off
takers. A consistent policy on this premise would allow forward minting across all sectors.
Relaxing the credit score threshold for potential customers to convince DOER of the efficacy of their inclusion for
SRECS II, forward minting may be offered. The state should keep in mind the TPO will be the guarantor of production not
the homeowner so it’s the sustainable business plan and creditworthiness of the TPO to examine or that of unknown
successor assignees of these Massachusetts resident’s lease contracts. TPO residential installations in Massachusetts
have gained significant market share as a result of the vacuum in conventional, regulated, financing tools for solar
consumers. The SRECS Forward minting incentive at a set, bankable value will succeed in filling that vacuum.
Some TPO companies in the residential field offer an ownership option. Confining the SRECS II, forward minting
incentive to only small system owners of the PV resource is not a restraint of their competitiveness in the market for
these customers.
DOER lack of clarity thus far on this very new policy initiative for an SRECS II forward minting incentive should be
remedied quickly. Every PV firm’s business plan must anticipate myriad details of how it will be managed and regulated.
The consequences of weak regulation , of letting the industry use it at will( basically creating another speculative
market within the SRECS II residential market) assures more confusion among PV consumers. Profiteering on their
innocence and ignorance by policy opportunists will damage the trust of all ratepayers. The viability of local, quality
design and installation PV service companies will be seriously damaged by allowing TPOS & aggregators to write the
menu for the forward minted SRECS II incentive and its finance options.
Thank you for considering my comments in policy decisions,
Sincerely,
Christopher Derby Kilfoyle
BPVS
Endnote: Non SREC Incentive
The Renewable Portfolio Standard ( RPS) allows purchase by suppliers and utilities of not just attribute
certificates ( RECS and SRECS) but actual electricity from renewable sources to meet compliance obligations. Normally,
residential, net metered, PV site accounts export such electricity to the grid daily, others on weekends . True tallying of
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actual decremented kilowatt hours ( kWh) is already practiced by one utility in their metering regimen. These whole
solar kilowatt hours ( whole meaning with their attributes intact) are then sold to other accounts by the utility and the
PV account is credited at near the retail rate. For PV sites who choose not to separate their attributes from the
electricity, the Non – SREC incentive, adds the source integrity to the retail rate in the net metering credit.
For example, a 5 kW system produces 5,755 solar kWh per year, two of every five kWh generated is exported
through and measured by the utility revenue meter. The utility reads this meter every month and in a years time the
account has exported 2,303kWh. In a direct transaction with the utility on their billing account, that 2,303 kWh is valued
at $0.41 per kWh, ( $0.125 adjusted retail value + $0.285 say for clean energy value or attributes) amounting to a
$944.23 credit per year. That’s $656.36 more than the normal net metering credit they would receive under current
regulations. The utility can apply the 2,303 solar kWh to their compliance obligation. Choosing this whole solar kWh (
Non-SREC) incentive for exports means the PV account holder cannot sell the attributes of the 3,452solar kWh they
used behind the meter. Their return on that is simply the value of deferred purchase from the grid.
Their incentive is much more modest than had they sold the attributes of their full solar production as SRECS but that
is better than nothing offered under the proposed SREC II plan and end of the Commonwealth Solar rebate. In fact the
credit for these exported whole solar kWh s could be higher at start and decline relative to the RPS Alternative
Compliance Payment (ACP) schedule . Despite the 3,452 solar kWh the account owner keeps for their ‘ personal’
renewable compliance obligation, society as whole is served from the emissions deferral of all their solar kWh
production.
The PV owner realizes authentic use of whole solar kWhs in house and a monetary bonus for
contributing whole solar kWhs to the grid. To those who think this ethical diligence is merely a semantic scruple over
the word ‘attributes’ , read the strictures of the Federal Trade Commissions Green Guidelines issued in December 2012.
http://www.ftc.gov/os/2012/10/greenguides.pdf
Institutions, organic farms, other businesses and individuals take seriously their environmental footprint from electricity
usage.
This non-SREC incentive should be extended as an option to all PV owner accounts and particularly those left
behind by the Solar Carve-out in 2010. It would encourage daylight hour electricity conservation on these accounts. The
net metering recovery surcharge could be modified for these accounts. Certainly the regulation should permit such
customers to opt for cash payments from the utility for excess credits and disallow PV capacity greater than 125% of
historic load on the account. This incentive is simpler to explain because it is more natural than separation of attributes
from electrons. There would be no aggregator or third party verification needed. An opt in term for the life of the PV
generation resource rather than the ten year SREC term would encourage its adoption.
Note s: Jan 26 2014The forward minting idea has been abandoned by DOER. BPVS presented oral comments at the Statehouse
stakeholders meeting on the SRECS II program on Friday Jan 24th 2014 . Our written comments will be copied
here after they are published on the DOER website.
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