Posts Tagged ‘MA’

DOER Files APS Regulations with Legislature

Posted October 16th, 2017 by SRECTrade.

On October 13, 2017, the Massachusetts Department of Energy Resources (DOER) filed an amended draft regulation with the Legislature’s Joint Committee on Telecommunications, Utilities and Energy. Pursuant to Chapter 251 of the Acts of 2014 and Chapter 188 of the Acts of 2016, the draft regulations add renewable thermal, fuel cells, and waste-to-energy thermal to the Massachusetts Alternative Portfolio Standard (APS). The filing follows two rounds of public hearing and comment periods occurring in the summers of 2016 and 2017. The draft regulation and accompanying guidelines are available on the DOER’s website here.

In response to stakeholder comments, the DOER made several revisions in the filed regulations. A brief summary of these changes is provided here, but the full redlined version is available for review here.

  • Woody Biomass: revised definitions and requirements, including fuel specification and performance requirements
  • Liquid Biofuels: reorganized quarterly caps to be distributed during each year and aligned requirements for Eligible Liquid Biofuels with the Environmental Protection Agency’s Renewable Fuel Standard (RFS)
  • Compost Heat Exchange Systems: added compost heat exchange systems as an eligible Renewable Thermal Generation Unit
  • Fuel Cells: revised efficiency threshold and modified eligibility for behind-the-meter, electric only, fuels cells to those interconnected to the Massachusetts electric grid
  • Multipliers for Non-Emitting Technologies: added multiplier for compost heat recovery systems and revised multipliers for intermediate and large, partial air source heat pump systems
  • Combination of Funding Provision: removed the combination of funding provisions and increased the maximum combination of funding percentage from DOER or any other state agency to 80%

In addition to the foregoing, the DOER made several technical edits and clarifications to reconcile language inconsistencies in the regulation and Guidelines. The DOER’s announcement of the filing is available here.

SRECTrade will continue to monitor the progress of the APS regulations and will provide updates as they are made available.

Final SMART Program Regulation Promulgated

Posted August 25th, 2017 by SRECTrade.

On Friday, August 25th, 225 CMR 20.00 Solar Massachusetts Renewable Target (SMART) Program was promulgated in the State Register. The Massachusetts Department of Energy Resources (DOER) posted the final version filed with the Secretary of the Commonwealth’s office to their website. The DOER announced that the final, promulgated version will be made available as soon as possible.

Following the promulgation of this regulation, the DOER anticipates that the electric distribution companies will jointly file a model tariff at the Department of Public Utilities (DPU), which will initiate a fully adjudicated proceeding at the DPU.

For more information on the final version of the SMART Program regulation, please visit our previous blog post on the topic here.

MA DOER Files Proposed Final Version of SMART Program Regulation

Posted August 11th, 2017 by SRECTrade.

On Friday, August 11th, the Massachusetts Department of Energy Resources (DOER) announced that it has filed its proposed final version of the Solar Massachusetts Renewable Target (SMART) Program regulation 225 CMR 20.00 with the Secretary of the Commonwealth’s Office. The DOER anticipates the final version will be published in the State Register on August 25, 2017, “with minimal to no changes”. The final but unofficial version of the regulation can be found on the DOER’s “Development of the Solar Massachusetts Renewable Target (SMART) Program” website here.

100 MW Procurement

Following comments regarding the initial 100 MW Procurement, which will be used to establish Base Compensation Rates for all participating SMART Solar Tariff Generation Units, the following changes were made to program design:

  • Each Distribution Company will issue one procurement for all projects sized 1 – 5 MW
  • All facilities in the procurement will be subject to a Ceiling Price of $0.17/kWh ($170.00/MWh)
  • Procurement results will establish unique Base Compensation Rates for the first Capacity Block of each individual Distribution Company, rather than establishing a single statewide Base Compensation Rate
  • The Base Compensation Rate for the first Capacity Block will equal the mean bid price received in each Distribution Company’s service territory

Compensation Rate Adder Caps and Rate of Decline

In its regulation filed on June 5, 2017, the DOER implemented an adder cap of 320 MW for each individual Compensation Rate Adder in an effort to “place boundaries around overall program costs”. In response to comments regarding these adder caps, the following changes were made:

  • Adder caps are eliminated
  • Each Compensation Rate Adder will decline by 4% for every capacity tranche established, and the Adder will not decline as Capacity Blocks are filled. The first capacity tranche for each Adder will equal 80 MW, with future segment sizes established by the DOER as they are filled

Project Segmentation

Following comments regarding the rules set forth by the DOER around parcel limits and project segmentation, the following modifications were made:

  • Added Canopy Solar Tariff Generation Units to allowable exceptions to rules, allowing canopies to be sited on same parcel as a Building Mounted Solar Tariff Generation Unit
  • Allow Solar Tariff Generation Units to be sited on adjacent parcels if owners can demonstrate to the DOER’s satisfaction that they are unaffiliated parties
  • Allow Solar Tariff Generation Units to span multiple parcels if located behind a single interconnection point, single meter, with a nameplate capacity of 5 MW or less
  • Added language to exempt projects from project segmentation rules if the applicant can demonstrate that necessary qualification documents were obtained by June 5, 2017
  • Added language that allows the DOER to exempt projects from project segmentation rules for good cause on a case by case basis

These project segmentation rules were initially established to prevent Solar Tariff Generation Units from manipulating program rules for their own financial benefit.

Land Use and Performance Standards

The DOER has also set forth rules to ensure that land use is considered when siting projects through the differentiation of incentive levels based on project location. In response to comments regarding these rules, the following changes were made:

  • Removed certain special provisions for Agricultural Solar Tariff Generation Units from the regulation; instead, these provisions are detailed in a separate Guideline
  • Added definition and special provisions for Floating Solar Tariff Generation Units, with an associated $0.03/kWh Compensation Rate Adder
  • Added language to exempt projects from being subjected to Greenfield Subcontractors if the applicant can demonstrate that necessary qualification documents were obtained by June 5, 2017
  • Classified all land that had been previously categorized as Category 1 Land Use, regardless of zoning
  • Clarified aspects of the performance standards requirements


In response to other comments received by stakeholders, the DOER also instituted the following changes:

  • Modified definitions of Community Shared Solar Tariff Generation Unit, Low Income Community Shared Solar Tariff Generation Unit, and Low Income Property Solar Tariff Generation Unit to clarify that Units will qualify as such if taking advantage of the alternative on-bill credit
  • Established a 35% per Capacity Block limit on the quantity of facilities with a nameplate capacity of less than or equal to 25 kW
  • Added language prohibiting capacity expansions, with specific exceptions
  • Provided further clarity regarding customer disclosure forms and added requirements regarding forms to special provisions for Community Shared Solar Tariff Generation Units and Low Income Community Shared Solar Tariff Generation Units
  • Modified timing of initial competitive procurement
  • Modified formula for calculating the incentive payments for Behind-the-Meter Solar Tariff Generation Units to be the sum of the three-year average of Basic Service Charges, in addition to current Distribution, Transmission, and Transition charges
  • Other technical updates and clarifying modifications

The DOER will notify stakeholders when the regulations have been published in the State Register in final official form.

MA Global Warming Solutions Act Regulations Promulgated

Posted August 11th, 2017 by SRECTrade.

On Friday, August 11th, the Massachusetts Department of Environmental Protection (MassDEP) published six final regulations to reduce statewide greenhouse gas emissions in the Massachusetts Register. These regulations follow the Supreme Judicial Court’s May 17, 2016 ruling in Kain v. DEP and Governor Baker’s September 16, 2016 Executive Order No. 569 (“Establishing an Integrated Climate Change Strategy for the Commonwealth”) to help ensure compliance with the 2020 statewide emissions limit established by the Global Warming Solutions Act (GWSA).

The six regulations and amendments include:

  • 310 CMR 7.72: Reducing Sulfur Hexafluoride Emissions from Gas-Insulated Switchgear (amended)
  • 310 CMR 7.73: Reducing Methane Emissions from Natural Gas Distribution Mains and Services (new)
  • 310 CMR 7.74: Reducing CO2 Emissions from Electricity Generating Facilities (new)
  • 310 CMR 7.75: Clean Energy Standard (new)
  • 310 CMR 60.05: Global Warming Solutions Act Requirements for Transportation (amended)
  • 310 CMR 60.06: CO2 Emission Limits for State Fleet Passenger Vehicles (new)

For more information on these regulations, including Fact Sheets, please visit the MassDEP website on the topic.

DOER Files SMART Program Emergency Regulation

Posted June 5th, 2017 by SRECTrade.

On Monday, June 5th, the MA Department of Energy Resources (DOER) filed an emergency regulation to implement the Solar Massachusetts Renewable Target (SMART) Program. The regulation is directed toward supporting the development of an additional 1,600 MW of solar energy generating facilities via a declining block program.

Although the emergency regulation takes effect immediately, it can only remain in effect for three months. The emergency regulation is a placeholder, pending a full rulemaking proceeding conducted by DOER, at which time the final program rules will be established. Following the conclusion of the DOER’s rulemaking process, the Department of Public Utilities (DPU) will need to conduct a proceeding for the DPU’s approval of the tariffs filed by the Electric Distribution Companies. Only after this rulemaking and proceeding take place will the SMART program be in effect. Accordingly, the SREC-II program remains in effect for all eligible solar facilities.

As a result of this implementation schedule, it is expected that solar facilities will be eligible to qualify for the SREC-II program through the end of Quarter 1, 2018.

For more information on the SMART program, please feel free to reference our last blog post on the topic here. The DOER’s official notice regarding this emergency regulation is available here.

DOER Announces Final SREC-II Factor Guidelines

Posted March 27th, 2017 by SRECTrade.

On Thursday, March 23rd the DOER provided an update on the finalized SREC-II program SREC Factors for projects over 25 kW that have not previously qualified for an SREC-II extension.

All SREC-II facilities that have a Statement of Qualification (SQA), but have not yet received an extension, will have their SQAs rejected. New applications may be submitted for these facilities, however, to seek an extension under these new guidelines. Any extension granted will be effective until March 31, 2018 at the following factors:


Please note that SREC-II systems with a capacity equal to or less than 25 kW will still receive an SREC Factor of 0.8, so long as they receive their authorization to interconnect before the effective date of the SMART program.

Facilities eligible for the extension are those that have not already received either a mechanically complete or 50% construction cost extension; facilities that can demonstrate that they are mechanically complete or commercially operational by March 31, 2018 will receive their respective SREC Factor listed above.

MA SREC-II Extension Webinar

Posted December 13th, 2016 by SRECTrade.

Earlier today, SRECTrade hosted a webinar covering the current state of the Massachusetts SREC-II program, key deadlines for qualifying systems under SREC-II, and SRECTrade application processes.

The application window is currently open for all MA systems, regardless of size, although qualification deadlines are approaching. Please feel free to reference SREC-II Extension Application Instructions HERE.

For access to the presentation slides, please click here: MA SREC-II Extension Webinar. To view a video recording of the webinar, please click the image below.

This document and recording is protected by copyright laws and contains material proprietary to SRECTrade, Inc. It or any components may not be reproduced, republished, distributed, transmitted, displayed, broadcast or otherwise exploited in any manner without the express prior written permission of SRECTrade, Inc. The receipt or possession of this document does not convey any rights to reproduce, disclose, or distribute its contents, or to manufacture, use, or sell anything that it may describe, in whole or in part. If consent to use these materials is granted, a link to the current version of this document on the SRECTrade website must be included for reference.

MA SREC-II Installer Webinar

Posted December 12th, 2016 by SRECTrade.

SRECTrade will be hosting a webinar this Tuesday, December 13th, at 2:00 PM EST. The webinar will cover the current state of the Massachusetts SREC-II program, key deadlines for qualifying systems under SREC-II, and SRECTrade application processes to consider as the program’s close approaches.

To attend the webinar click HERE to register. A recording will be made available on SRECTrade’s blog for those unable to attend.

MA DOER Seeking Comments on Next Generation Solar Incentive Straw Proposal

Posted October 25th, 2016 by SRECTrade.

On September 23, 2016, the Massachusetts Department of Energy Resources (DOER) presented its Straw Proposal to outline its vision for the next solar incentive program for the state. The DOER is proposing to shift away from the state’s successful SREC program, which has created one of the largest and most robust solar markets in the country.

Under the DOER’s proposal, a declining block feed-in-tariff would be established in regulated utility territories, and a separate program would be created for municipal light districts. Moving away from the current market-based framework will impose a substantial transition burden and introduce new costs to participants. The shift to a completely different program will have a negative impact on the viability of the solar industry in the interim and poses uncertainty moving forward.

Massachusetts has installed more than 1,200 MW of operational solar capacity to date and was ranked 2nd in the nation in total solar industry employment in 2015. Replacing the current market-based framework with a declining block feed-in-tariff will not only be costly to all stakeholders, but it will also fail to satisfy the DOER’s objective to “provide clear policy mechanisms that control ratepayer costs and exposures”. By imposing this new and complicated model, the DOER will force the state’s many market participants to manage, understand, and abide by multiple programs at once. This will undoubtedly increase soft costs and increase administrative burden across the industry.

In contrast, establishing an SREC-III program would allow the state’s solar industry to continue relying on a market-based policy to set incentive levels and forge ahead on its path to a stable, equitable, and self-sustaining solar market. By making adjustments to SREC factors, market sectors, the SCCA and SACP, the Commonwealth can continue to benefit from the successful SREC model and preserve the progress it has made since SREC-I was implemented six years ago.

SRECTrade encourages all stakeholders in the Massachusetts solar market to submit comments in support of a smooth transition to another successful SREC program. Comments can be submitted to the DOER via email at and must be submitted by this Friday, October 28th.

DOER Announces Final 2017 Compliance Obligation and Minimum Standard

Posted September 1st, 2016 by SRECTrade.

On Wednesday, August 31, the Massachusetts Department of Energy Resources (DOER) announced the final 2017 Solar Carve-out (SREC-I) and Solar Carve-out II (SREC-II) Compliance Obligations and Minimum Standards. This announcement follows the results of the SREC-I and SREC-II Solar Credit Clearinghouse Auctions.

Notably, this announcement differs greatly from the preliminary announcement in July. In particular, the DOER announced that the final SREC-II Minimum Standard for load under contracts signed prior to May 8, 2016 is 2.0197% (969,635 MWhs), reduced from 2.2960% (1,102,311 MWhs).

Solar Carve-out (SREC-I)

The DOER has determined that the 2017 Compliance Obligation for the SREC-I program will be 783,183 MWh and that the Minimum Standard will be 1.6313%. The 2017 Minimum Standard for load under contracts signed before June 28, 2013 will be 0.9861%. The Determination of the CY 2017 Total Compliance Obligation and Minimum Standard, published by the DOER, outlines how this Minimum Standard was calculated.

SREC-I Min Std

Solar Carve-out II (SREC-II)

The DOER has also calculated the 2017 Compliance Obligation and Minimum Standard for the SREC-II program, which are 1,374,406 MWh and 2.8628%, respectively. The DOER outlined how this preliminary Minimum Standard was determined in its “CY 2017 Calculation of Minimum Standard Guideline”.


Since all Retail Electricity Suppliers are exempt from additional obligations resulting from the expansion of the SREC-II Program Capacity Cap, the DOER established a baseline Compliance Obligation and Minimum Standard for load under contracts signed on or prior to May 7, 2016. The DOER’s calculation of the Final 2017 Compliance Obligation and Minimum Standard were similar to its calculation of the Preliminary 2017 Compliance Obligation and Minimum Standard (detailed here), but used 825 MW as the capacity that it expects would have been in operation had the SREC-II Program Capacity Cap not been expanded. The DOER used the 825 MW value to reflect its estimate of the generation facilities that would be qualified and operational by the end of the year – a significant reduction from the original 947 MW projection.

Using the 825 MW estimate, the DOER determined a total baseline Compliance Obligation of 969,635 MWhs and a Minimum Standard of 2.0197%. These two figures are significantly less than their counterparts from the preliminary 2017 Compliance Obligation and Minimum Standard, which were 1,102,311 MWhs and 2.2960%, respectively.

SREC-II Obligation Chart

The latest Solar Carve-Out II Qualified Units report (updated on August 25) identified nearly 575 MW of capacity as qualified and operational under the SREC-II program. Comparing the 825 MW figure that the DOER is targeting to the existing 575 MW, the market would need to more than double the Last Twelve Months (LTM) monthly average build-rate (30 MW) to reach that threshold.

For more information on the July announcement of the Preliminary 2017 Compliance Obligation, please visit our blog post on the topic.