On 2/27/2013 the Massachusetts Department of Energy Resources (DOER) released proposed changes to the RPS Solar Carve-Out program. The change-tracked version of the proposed rules can be viewed here. Interested parties can submit comments to DOER.SREC@state.ma.us with the word COMMENTS in the subject line from March 1st until 5:00 PM on March 25th. A public hearing will be held on March 22nd in the Gardner Auditorium, Massachusetts State House in Boston from 1:00pm to 3:00pm.
The proposed changes to the rules fall into two general categories: 1) updates to the existing program and 2) changes to smooth the approach to the 400MW program cap. The following is a brief summary of the proposed changes:
- Change to allow anyone to deposit an SREC in the Clearinghouse Auction, not just the original SREC owner.
- Clarification that reminted SRECs coming out of a Clearinghouse Auction can’t be submitted to any future auctions.
- Direction to the DOER to develop an assurance process that will allow proposed systems a spot under the 400MW limit as long as they follow certain steps. This will probably be very similar to the net metering process that was recently enacted.
- Details were provided on the conditions necessary for a rebuilt system to qualify as new.
- A change was made to the formula used to determine each year’s SREC requirement, removing the “SACP volume” portion of the formula. In the original rule, the next years’ standard was adjusted by subtracting SACPs paid in the two years prior. The formula change would be retroactive to 2013, although there is protection for electric distribution companies with existing contracts. It also includes a novel mechanism by the DOER to purchase a like number of SRECs protected under this clause so that there will be no impact on total demand from the sheltering of existing contracts. Click here for a more comprehensive explanation of this formula adjustment.
- Some minor changes were made to the calculation used to determine annual SREC requirements after reaching 400MW using the existing base to determine the capacity factor rather than the calculated number used before. Also minor changes on what happens the last year of the program if SRECs are entered into the auction that year.