Letter to the Solar Transition Work Group in Response to the OCE Staff Straw Proposal released on March 6, 2012

March 8th, 2012

Submitted March 7, 2012

Dear Mr. Winka,

Thank you for your efforts to date in facilitating the Solar Transition Working Group. We are writing to you in order to make several suggestions to the OCE Staff Straw Proposal released on March 6, 2012, as well as to voice several concerns regarding issues we did not see mentioned in the Straw Proposal. We understand that the purpose of this Straw Proposal is not to fix all obstacles facing the New Jersey solar industry, but we believe this is as good a time as ever to address the following issues:

  • Treatment of usable farmland – As you may know, Southern New Jersey is home to substantial farmland acreage. A portion of this farmland is currently not farmed, and a small percent of this unused portion had been approved for housing developments before the economic downturn. However, most of the developments never came to fruition, and now New Jersey farmers are eager to participate in the burgeoning solar industry, but farmland classification and zoning procedures are unclear. We would like to see clearly established procedures defining which organizations, and what criteria will be employed to identify “usable” farmland.
  • Adjustable SREC Scale – We believe extending the EDC SREC program by the suggested capacity will do little to support a suffering, but determined solar industry. This does not eliminate the static demand curve that was partially responsible for the downturn in the New Jersey SREC market? The Board and OCE should take this opportunity to re-examine the SREC market structure, and create a mechanism that will prevent future market collapse. As proposed by the Rutgers CEEEP team several months ago, an adjustable SREC target that uses past years capacity installation data to determine the upcoming SREC target, combined with a reduced ACP, will prevent future SREC market collapse, and allow New Jersey to hit its RPS target in an economically responsible manner.

Solar PV has the potential to save New Jersey cities and towns a significant amount of money on utility bills. This should not be overlooked when examining the SREC market, especially in a world of constrained budgets. We believe a provision for “community solar” should be included in the SREC carve-out.

  • Community Solar – Cities and towns should be encouraged, via a community solar carve-out to host solar arrays. Contracting solar power is an effective way to hedge against future electricity price increases, and save money in the present as well. This will allow municipalities to spend less on utilities and more on vital, municipal programs.
  • In order to give New Jersey cities and towns the lowest energy price possible, long-term SREC contracts should be available to community project developers.

Thank you for your time,

Regards,

Clay Rager

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