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ARTICLE · 03 OCTOBER 2016

DOER's Solar Incentive Straw Proposal: Optimism, Anxiety, Uncertainty.

On September 23, DOER presented a straw proposal for the next phase of Massachusetts solar incentives.

United StatesEnvironment

On September 23, DOER presented a straw proposal for the next phase of Massachusetts solar incentives. DOER's ambitious proposal for a tariff-based program reflects a thoughtful development process and a laudable goal of crafting a program that is more efficient at promoting sustained solar deployment. There is plenty to like. But, DOER has bitten off quite a mouthful by proposing a structure that departs so dramatically from the SREC approach. Massachusetts stakeholders have seven years of experience with SRECs; a tariff-based program will be something new.

Given the novelty and complexity of DOER's proposal, the biggest concern among solar developers may not be that DOER is unable to design a workable new program, but that DOER is unable to complete the design and implementation of its new program in time to avoid a period of policy uncertainty that stalls the development of new projects. Even aside from worry about an actual gap in incentive eligibility between the

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