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
Other
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.
