Posts Tagged ‘Massachusetts’

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 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.

Massachusetts Solar Credit Clearinghouse Auction Announcement – Summer 2017

Posted June 21st, 2017 by SRECTrade.

On June 16th, the DOER formally announced that they would conduct Solar Credit Clearinghouse Auctions (SCCA) for both the SREC-I and SREC-II programs.

EnerNOC Inc. posted the Auction Notice and Qualification Application for this year’s SCCA to the Auction Announcement Website. The SCCA is a market mechanism that allows for any leftover SREC supply from the previous compliance year to be sold to buyers. In years of oversupply, the DOER will consider the total volume of SRECs submitted to the SCCA, as well as the success of the auction in clearing those volumes, in their decision to increase the RPS demand for future compliance years.  Since there will be a SCCA for compliance year 2016, we know that the 2018 obligation will be adjusted higher.

Price

This year’s fixed price for buyers is set at $300 for both SREC-I and SREC-II. After the DOER administration fee, sellers will receive a net amount of $285 per SREC. Beginning next year, the SREC II SCCA price will begin to decrease while the SREC I price will remain at $300.

Volume

The volumes of certificates available for purchase through each auction are as follows:
MA16 SREC I: 14,405 certificates
MA16 SREC II: 234,057 certificates

Tiers

The auction will consist of two tiers:

The first tier (Tier I) includes all natural compliance buyers. Up to 50% of the total auction volume will be reserved for Tier I bidders. If demand exceeds the 50% benchmark, awards will be made on a pro-rata basis. If there is insufficient demand from Tier I bidders, the remaining SRECs will be made available to Tier II bidders.

The second tier (Tier II) of bidders include all other entities, including Tier I entities with unfulfilled bids from Tier I. After Tier I awards have been given, the remaining SRECs will be allocated to Tier II bidders on a pro-rata basis.

Key Dates & Bidder Webinar Registration

  • Wednesday, June 21, 2017 – Bidder webinar to review auction process and the Qualification Application
    • To register for the webinar please follow this link
  • Wednesday June 28, 2017 – Bidder Qualification Application due
  • Monday, July 24, 2017 – First auction takes place

We will keep you posted with any new updates ahead of the auction, and the results of the auction as soon as they are made publicly available.  Feel free to reach out to your coverage on the SRECTrade brokerage desk to discuss any questions you may have about the upcoming auction.

 

Disclaimer. This document, data, and/or any of its components (collectively, the “Materials”) are for informational purposes only. The Materials are not intended as investment, tax, legal, or financial advice, or as an offer or solicitation for the purpose or sale of any financial instrument. SRECTrade, Inc. does not warranty or guarantee the market data or other information included herein, as to its completeness, accuracy, or fitness for a particular purpose, express or implied, and such market data and information are subject to change without notice. Past performance should not be taken as an indication or guarantee of future performance, and no representation or warranty, express or implied, is made regarding future performance. Any comments or statements made herein do not necessarily reflect those of SRECTrade, Inc. SRECTrade, Inc. may have issued, and may in the future issue, other communications, data, or reports that are inconsistent with, and reach different conclusions from, the information presented herein.

Copyright. This document is protected by copyright laws and contains material proprietary to SRECTrade, Inc. This document, data, and/or any of its components (collectively, the “Materials”) may not be reproduced, republished, distributed, transmitted, displayed, broadcasted or otherwise disseminated or exploited in any manner without the express prior written permission of SRECTrade, Inc. The receipt or possession of the Materials 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 the Materials is granted, reference and sourcing must be attributed to the Materials and to SRECTrade, Inc. If you have questions about the use or reproduction of the Materials, please contact SRECTrade, Inc.

Massachusetts SREC-II Update – January 2017

Posted January 23rd, 2017 by SRECTrade.

Over the last month the market received both a new list of SREC-II qualified projects as well as more precise information on Q3 SREC generation. As such, we have updated our capacity models to reflect the new information.

Please find our updated capacity presentation here.

The Massachusetts Department of Energy Resources (DOER) recently published their periodic update on registered SREC-II capacity on December 12, 2016, and Q3 2016 SRECs were issued on January 15th, 2017.  These data points provide more precise information around the current build rates and the exact amount of SRECs currently available for sale, but the data simply confirms the widely known fact that MA16 SREC-II is indeed heavily oversupplied.

Given an oversupply from 2015 of 66,372 SRECs, plus the 441,890 SRECs issued in Q1, Q2 and Q3 of 2016 (Q3 generation was 190,526), we are left with a total of 508,262 SRECs already created.  That alone leaved the market 49% over the exempt-load obligation for 2016.  Using the trailing twelve month average for new capacity added per month, we add another 143,887 SRECs as an estimate of Q4 production to bring us to a grand total of 652,149 SRECs created in 2016.  This represents a 312,069 SREC oversupply, or approximately 92% of the 2016 compliance obligation.

ma16-srec-ii-sd

We expect the DOER to publish an updated qualified project list in the near future.  Additionally, we expect more information in the coming weeks on the status of the SREC-II extension program.  As either of those updates come available we will be sure to pass on all relevant information.  As always, feel free to reach out to your SRECTrade sales coverage for any questions or comments.

 

Disclaimer. This document, data, and/or any of its components (collectively, the “Materials”) are for informational purposes only. The Materials are not intended as investment, tax, legal, or financial advice, or as an offer or solicitation for the purpose or sale of any financial instrument. SRECTrade, Inc. does not warranty or guarantee the market data or other information included herein, as to its completeness, accuracy, or fitness for a particular purpose, express or implied, and such market data and information are subject to change without notice. Past performance should not be taken as an indication or guarantee of future performance, and no representation or warranty, express or implied, is made regarding future performance. Any comments or statements made herein do not necessarily reflect those of SRECTrade, Inc. SRECTrade, Inc. may have issued, and may in the future issue, other communications, data, or reports that are inconsistent with, and reach different conclusions from, the information presented herein.

Copyright. This document is protected by copyright laws and contains material proprietary to SRECTrade, Inc. This document, data, and/or any of its components (collectively, the “Materials”) may not be reproduced, republished, distributed, transmitted, displayed, broadcasted or otherwise disseminated or exploited in any manner without the express prior written permission of SRECTrade, Inc. The receipt or possession of the Materials 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 the Materials is granted, reference and sourcing must be attributed to the Materials and to SRECTrade, Inc. If you have questions about the use or reproduction of the Materials, please contact SRECTrade, Inc.

MA16 SREC-I Market Review

Posted November 3rd, 2016 by SRECTrade.

With the October issuance of Q2 2016 SRECs behind us, we are now approximately halfway through the 2016 energy year in Massachusetts. This blog post will take into account observed issuance numbers from the first half of the year and use projections for future issuance periods to understand what caused the fall in MA16 SREC-I prices from $450+ in January to more recent bids of $380. We will look at the supply and demand balance in order to survey what may be coming in the months ahead.

Recall that demand is driven by retail electric sales in the State. The latest data we have comes from 2014, a year in which 48,129,294 MWh were sold. If we assume that retail electricity sales are flat and we apply the obligation of 1.76% and then adjust for exempted load, we derive a total estimated demand of 833,780 SRECs:

MA16 SREC-I Demand

On the supply side of the market, the simplest analysis assumes the market generates nearly 784,000 SRECs and when combined with the re-minted volumes from this year’s SCCA (1,898), then we get a total supply of 785,886. When compared to the demand outlined above, we conclude the market is short nearly 48,000 SRECs.

MA16 REC-I simple supply

What would explain falling prices in a market that is potentially under-supplied? The quick answer is that perhaps retail sales of electricity are falling instead of flat, which would lower the demand. Alternatively, perhaps the supply of SRECs is higher than detailed. We’ll examine some supply scenarios first.

One component of supply is the banked SRECs from prior years. Retail suppliers can bank up to 10% of their annual obligation for use in future years. The maximum volume of banked RECs in the market is estimated at 65,382 – the sum of the total obligation in 2014 and 2015 multiplied by 10%. If all of those SRECs were brought to market in 2016, then we would see the market long by 17,488 SRECs. We see that scenario as unlikely since 2015 was short and the bank may have been used to avoid paying Alternative Compliance Payments (ACPs). On the other hand, it’s possible that between re-minted SRECs from the 2013 and 2014 SCCCA and banked volumes, that upwards of 15,000 SRECs from prior vintages may impact the 2016 market. This source of supply would help to tighten the balance of supply and demand, but not necessarily push to over-supply.

Examining a different scenario on the demand side, even if retail sales were down 3%, the total SREC demand would still sit at 808,414, leaving a tight, yet still under-supplied market based on the simpler supply analysis.

Another element worth mentioning is liquidity. While a healthy market needs liquidity from both buyers and sellers in order to function properly, we will direct our attention to the buy-side. Because there are far more sellers than buyers in this market, an absence of even a handful of buyers is far more impactful to the efficiency of the SREC markets than the absence of an equivalent number of sellers.

In recent months we have observed a noticeably subdued level of activity from buyers. What happens when SRECs are issued and a bunch of sellers come into a quiet market? As evidenced from pricing over the last month, bids start to retreat:

Market_Insights___SRECTrade

A simplistic read of the current state of the market is that prices have dropped due to the possibility of oversupply. However, deeper examination of current supply and demand in SREC-I markets points towards a tighter, more balanced market. The bearish sentiment reflected in recent weeks may actually reflect a lack of activity from natural compliance buyers in the face of a glut of supply coming to market after Q2 issuance. These two scenarios mean very different things for medium to long term “equilibrium” pricing in the SREC-I market. A structural and persistent oversupply, a scenario we do not perceive as likely, would mean that lower prices are justified and here to stay. A mismatch of liquidity due to trading preferences of buyers and sellers however would point towards short term volatility but longer term stability in supportive SREC prices.

As always, we will continue to provide follow-up analysis as more information becomes available.  Feel free to reach out to your contacts on SRECTrade’s brokerage desk with any questions you may have.

 

Disclaimer. This document, data, and/or any of its components (collectively, the “Materials”) are for informational purposes only. The Materials are not intended as investment, tax, legal, or financial advice, or as an offer or solicitation for the purpose or sale of any financial instrument. SRECTrade, Inc. does not warranty or guarantee the market data or other information included herein, as to its completeness, accuracy, or fitness for a particular purpose, express or implied, and such market data and information are subject to change without notice. Past performance should not be taken as an indication or guarantee of future performance, and no representation or warranty, express or implied, is made regarding future performance. Any comments or statements made herein do not necessarily reflect those of SRECTrade, Inc. SRECTrade, Inc. may have issued, and may in the future issue, other communications, data, or reports that are inconsistent with, and reach different conclusions from, the information presented herein.

Copyright. This document is protected by copyright laws and contains material proprietary to SRECTrade, Inc. This document, data, and/or any of its components (collectively, the “Materials”) may not be reproduced, republished, distributed, transmitted, displayed, broadcasted or otherwise disseminated or exploited in any manner without the express prior written permission of SRECTrade, Inc. The receipt or possession of the Materials 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 the Materials is granted, reference and sourcing must be attributed to the Materials and to SRECTrade, Inc. If you have questions about the use or reproduction of the Materials, please contact SRECTrade, Inc.

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 DOER.SREC@state.ma.us 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”.

SREC-II Min Std

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.

MA DPU Establishes Net Metering “Notification Date” as September 26, 2016

Posted August 3rd, 2016 by SRECTrade.

On July 29, 2016, the Massachusetts Department of Public Utilities (the “DPU”) issued its Order Announcing Notification Date and Directives to Distribution Companies in its proceeding under 16-64-D, establishing the Net Metering “Notification Date” as September 26, 2016. Pursuant to Chapter 75 of the Acts of 2016D.P.U. 16-64-C, and as confirmed by this Order, there are three strict criteria that must be met for a private net metering project to receive net metering credits under the old regime:

  1. Submission of an Application for Cap Allocation (ACA) to the Massachusetts System of Assurance of Net Metering Eligibility (System of Assurance) for a net metering cap allocation prior to the Notification Date of September 26, 2016 by 2:00pm;
  2. Receipt of confirmation from the System of Assurance Administrator that the application (ACA) is complete; and
  3. Receipt of a ACA cap allocation by January 8, 2017.

In its Order, the DPU determined that “the best option to result in a smooth transition to a stable and equitable solar net metering market” was to align the timing for transition to the new net metering credits policy with the Massachusetts Department of Energy Resources (DOER)’s SREC-II program. In selecting September 26, 2016 as the “Notification Date”, the DPU calculated the maximum amount of time that could be required to obtain a cap allocation on or before January 8, 2017, which was determined to be 70 business days. In addition, the September 26 date is exactly 60 calendar days after the Order’s announcement of the Notification Date. In consideration of these two timelines, the DPU determined that this date would provide enough time for systems to plan for, apply for, and receive a net metering cap allocation under the existing framework.

For more information on the current and new net metering regulation in the state of Massachusetts, please visit our previous blog post on the topic.

MA DOER Announces Preliminary 2017 Compliance Obligation

Posted July 25th, 2016 by SRECTrade.

Friday, July 22, 2016, the Massachusetts Department of Energy Resources (DOER) announced the preliminary 2017 Solar Carve-out (SREC-I) and Solar Carve-out II (SREC-II) Compliance Obligations and Minimum Standards. Customarily, the DOER estimates these values prior to administering the Solar Credit Clearinghouse Auction each year. The final 2017 Minimum Standards will be announced on or before August 30th, after both the SREC-I and SREC-II Auctions have concluded.

Solar Carve-out (SREC-I)

Notably, the DOER projects that the final 2017 Compliance Obligation for the SREC-I program will be approximately 783,181 MWhs and that the Minimum Standard will be approximately 1.6313%. These values will be increased to 785,077 MWhs and 1.6352%, respectively, if the SREC-I auction does not fully clear in the first two rounds. The 2017 Minimum Standard for load under contracts signed before June 28, 2013 will be 0.9861%.

The DOER published a resource outlining its calculation of the preliminary SREC-I Minimum Standard.

Preliminary 2017 Compliance Obligation SREC-I Table

Solar Carve-out II (SREC-II)

Regarding the SREC-II Program, the DOER established a baseline Compliance Obligation and Minimum Standard that would have applied to Retail Electricity Suppliers had the RPS Class I Emergency Regulation not been filed on April 8, 2016; these suppliers are exempt from any additional obligations resulting from the expansion of the SREC-II Program Capacity Cap.

To calculate this baseline Minimum Standard, the DOER first determined the expected MWh/year that would have resulted had the SREC-II Program Capacity Cap remained 947 MW by:

  1. Identifying the percentage shares of MW currently qualified under each SREC-II Market Sector;
  2. Multiplying these percentages by the original 947 MW SREC-II Program Capacity Cap;
  3. Multiplying these totals by (1) their respective SREC Factors, (2) a 13.51% expected capacity factor, and (3) 8,760 hours/year.

The DOER then summed these values and combined the auction volume and banked SREC-II volume from the 2015 Compliance Filings, resulting in a baseline Compliance Obligation of 1,102,311 MWhs and a Minimum Standard of 2.2960%. These values will be increased to 1,169,357 MWhs and 2.4357%, respectively, if the SREC-II auction does not fully clear in the first two rounds.

Preliminary 2017 Compliance Obligation SREC-II Table 2

Additionally, the DOER calculated the preliminary 2017 SREC-II Compliance Obligation and Minimum Standard for load under contracts signed after May 8, 2016 – 1,496,188 MWhs and 3.1164%, respectively. These values will be increased to 1,563,234 MWhs and 3.2561% if the SREC-II auction does not fully clear in the first two rounds.

Preliminary 2017 Compliance Obligation SREC-II Table

The DOER also published a resource outlining its calculation of the preliminary SREC-II Minimum Standard.

Solar Credit Clearinghouse Auctions

The first rounds of the SREC-I and SREC-II Solar Credit Clearinghouse Auctions are scheduled for July 29, 2016. A second and third round will be held as needed the following week should these auctions not fully clear.

The DOER has also provided slight updates to the volumes of SRECs available in the Auctions: 1,896 in SREC-I and 67,046 in SREC-II.

SRECTrade will continue to monitor the proceedings of the Solar Credit Clearinghouse Auctions and will report the outcomes of the Auctions once the results become readily available.

MA Department of Public Utilities Clarifies Net Metering Regulation

Posted May 25th, 2016 by SRECTrade.

Please note this blog post has been revised from the original May 24, 2016 post.

On Wednesday, May 18th, the Massachusetts Department of Energy Resources (DOER) notified the Department of Public Utilities (DPU) of its intent to file its determination that the 1,600 Megawatt (MW) threshold will be met on or about June 1, 2016 and requested that the DPU clarify whether facilities with private cap allocations on or before the “Notification Date” will receive the current net metering credits or the new Market Net Metering Credits. Under the recently enacted Chapter 75 of the Acts of 2016, this determination sets into motion DPU’s charge to establish a “Notification Date”, which will serve as a deadline for systems that are under the private net metering cap to be interconnected or allocated under the cap in order to receive the current net metering credits. Furthermore, the DOER requested that the DPU clarify its Emergency Net Metering Regulations and assure those facilities in receipt of net metering cap allocations on or before the Notification Date that their projects will receive net metering credits at current rates and will not receive Market Net Metering Credits (which are effectively equal to 60 percent of the retail rate). Prior to the DOER’s request, the uncertainty around the Notification Date deadline left private-cap projects in advanced stages of construction at risk of receiving Market Net Metering Credits if they failed to be interconnected by the Notification Date, creating project financing concerns.

In its May 19th Order Clarifying Emergency Net Metering Regulations, the DPU formally recognized that systems obtaining a private net metering cap allocation are “on the path toward interconnection”, since these allocations are assurances that a system will receive net metering services upon authorization to interconnect. In clarifying its policy on net metering credit eligibility, the DPU extended retail rate credit eligibility for projects that receive a private cap allocation by the Notification Date, even if those projects are not yet interconnected. Resultantly, for the duration of the Emergency Net Metering Regulations, Solar Net Metering Facilities that are interconnected or in receipt of a private cap allocation from the System of Assurance by the Notification Date shall receive retail rate net metering credits (that is, Net Metering Credits as defined in 220 C.M.R. § 18.04(1) and (5)).

This interpretation of eligibility will remain in effect only for the effective period of the Emergency Net Metering Regulations, and it is highly probable that the Notification Deadline will be set by the DPU for a date later than June 1, 2016. Following notice by the DOER that the 1,600 MW cap has been allocated, the DPU will solicit comments on the Emergency Net Metering Regulations and related issues, conduct a public hearing, and enact Final Net Metering Regulations effective July 29, 2016. Accordingly, it is possible that the Notification Deadline will be set as July 29, 2016 or possibly later than this date.

In accordance with the Order, facilities under the private net metering cap that fail to meet the Notification Date deadline will receive Market Net Metering Credits. Residential projects 10 kW and smaller on single-phase circuits, or systems under 25 kW on 3-phase circuits, will be exempt from the new rate structure under Sections 7 and 8 of the Act and are guaranteed retail remuneration rates. To be clear, facilities under the public net metering cap will continue to receive net metering credits at the current rates and will not be impacted by this Notification Deadline. For more information on current net metering and other solar legislation in Massachusetts, please visit our previous blog post on the topic here.