Some projections show installed PV capacity eligible for the MA Solar Carve-Out Program, otherwise known as the MA SREC program, reaching 400 MW as early as 2014. Once the current SREC market reaches 400 MW no other projects will be eligible for participation in the current program. In preparation for the approach of the 400 MW cap, the DOER held a “Post-400 MW Solar Policy Stakeholder Meeting” in Boston on March 22, 2013, attended by SRECTrade’s own Alex Sheets.
The purpose of the meeting was to discuss the DOER’s post-400 MW program proposals, including the need for additional clarifications on an “Assurance of Qualification” queuing process for projects wishing to participate in the current iteration of the SREC program. After the meeting’s conclusion, the DOER requested additional formal comments and suggestions. The DOER has since issued guidance on Assurance of Qualification process as well as public comments on the size and shape of a solar incentive program after the 400 MW cap is reached for the current program.
Assurance of Qualification Guideline
In its April 12, 2013 email the DOER summarized the main points of its draft Assurance of Qualification (queuing process) proposal. The draft guideline can be viewed here and we reprint the DOER’s own draft bullet points here:
- Establishes a list of criteria for determining what constitutes a “complete” application.
- Creates an exception for small generation units (<30kW DC) that exempts them from meeting the same criteria that larger projects must meet in order to qualify.
- Establishes a set-aside of the 400 MW DC program cap specifically for small generation units that is equal to 60 MW DC. This 60 MW set-aside includes just over 30 MW of small generation units that are already qualified and operational and helps ensure that the residential and small commercial sector will be protected from any market disruptions in the event the 400 MW program cap is reached before a new program is in place.
- Establishes a reservation period of 9 months for projects that have obtained an Assurance or Statement of Qualification. Units must be interconnected within this reservation period or will lose their Assurance or Statement of Qualification. It also provides for extensions of this reservation period in certain situations.
- Creates a list of permissible and prohibited changes that can be made to a project after it receives its Assurance or Statement of Qualification.
Post-400 MW Solar Policy Proposals
The DOER posted all written proposals for a post-400 MW program here. A wide spectrum of proposals were submitted. However, suggestions predictably ranged from the implementation of a feed-in-tariff program to the development of a parallel SREC program, similar to the current one. In general it appears that the majority of stakeholders support the continued implementation of an SREC-based policy.
SRECTrade will continue to closely monitor the development of both post-400 MW policy as well as the Assurance of Qualification process and will periodically update this blog with updates.
