Find additional information on the SMART Program, plus workbooks, interconnection resources and more.
Find the latest SMART Program Regulations and Guidelines, plus definitions.
Click here for the latest SMART Program Regulations.
Click here for the latest SMART Program Guidelines.
A full list of program terminology and official definitions are available in the program regulations 225 CMR 20.00. Here are some of the top acronyms and definitions.
For support in submitting your SMART Application/Claim, please contact CLEAResult at 888-989-7752 or email [email protected].
For specific interconnection, metering, billing inquiries, etc., related to your SMART project(s), please reach out to the appropriate EDC as follows:
For specific inquiries requiring the DOER’s input or guidance, please email their SMART inbox at [email protected].
Section A: Dates/Timing/Application
After a project has been acceptedby the SMART Program, how long does that project have to become operational? Is there a reservation period?
The Reservation Period is 12 months after the preliminary Statement of Qualifications has been issued. The project must be completed within that timeframe or must apply for an extension and possibly need to pay an additional fee, or the Reservation will be cancelled. Please refer to the Statement of Qualification Reservation Period Guideline [HERE] for more information.
What kinds of projects are eligible to qualify for a Reservation Period extension? Is there a fee associated with an extension? Is the fee reimbursable?
Any project may apply for an extended Reservation Period of up to six months at a fee of $25 per kW. The Reservation Period extension fee is refundable if the project is completed within the extended Reservation Period. If the project cannot demonstrate that it became mechanically complete within the extended Reservation Period, the project’s Statement of Qualification will expire and the fee will be forfeited. Any forfeited fees will be retained by the applicable EDC to offset administrative costs.
Please refer to the Statement of Qualification Reservation Period Guideline [HERE] for more information about Reservation Period extensions for legal challenges, utility delays, and good cause.
Does a SMART Applicant have to be a Massachusetts based company?
No, the Applicant and/or System Owner do not have to be based in Massachusetts. However, the host site does have to be interconnected to one of the distribution system of a participating electric distribution company (EDC).
Does the project have to be in Massachusetts or can it be located anywhere in ISO NE?
Projects must be located in Massachusetts and interconnected to the distribution system of a participating EDC.
Can you provide details on application fees (upon submission of application) and developer’s security deposits (upon PPA execution)? At what point in the application process is the fee due? Is the fee reimbursable? Will the application fee be a fixed number or will it vary based on the size of the project?
An application fee will be required when submitting an application and will be payable via credit card or debit card through the application portal. The fee structure is tiered based on the five project size categories in the SMART program as follows:
There will not be a performance guarantee or security deposit required for the regular SMART Program; that was only required for the competitive RFP process which was completed in January 2018. The application fees will not be refunded if the application is denied, withdrawn, or for any other reason.
Are credit cards the only option for paying the application fee?
Credit cards or debit cards are the only method of payment accepted to pay the application fee. The secure online payment portal utilizes the Stripe payment processing system and will accept Visa, Mastercard, American Express, Diners Club, Discover, and JCB.
What happens at the end of the 10 and 20 year tariff terms?
The SMART Program incentive payments will end after 10 years for systems 25 kW and smaller, or after 20 years for systems larger than 25 kW. The systems will no longer have any SMART Program obligations or direct program benefits after their term has been completed. The ownership rights to the Class I RECs will revert to the system owner following the end of the tariff term, and at that time the owner may sell Class I RECs on their own.
How quickly will projects be issued their Preliminary SQs? What is the time frame for receiving the final SQ after filing the claim application?
Applications or claims will be evaluated and processed on a rolling basis that is expected to typically be completed within 2 – 3 weeks after a complete and accurate application is submitted.
Can the project size deviate at the claim stage from the size at which it originally received in the preliminary SQ?
The final as built AC size of a given project may not exceed the AC capacity reserved with the preliminary SQ, but it may be less than the originally reserved AC capacity. The final as built DC size of a project may exceed the DC capacity reserved, so long as the AC size of the project has not increased.
Section B: PowerClerk Application and Claim Portal
Does PowerClerk have the ability to create an account for a single company, allowing individual employee accounts to submit applications and see other projects under the company? Stated another way, can multiple employees at a company share an account to submit applications?
No, each user must have their own unique account using their own email. Users can grant other users access to their projects using the “Grant Access” functionality on the project landing page.
Is there a limit to the size of files I can upload to the portal?
Yes, the limit to each individual file uploaded into PowerClerk is 25 MB. If you have a larger file, it must either be condensed or broken into 2 or more smaller files. If an additional file upload is needed for this, or for any other, purpose, there are additional file upload slots available in the application portal.
If my specific inverter or modules are not listed and I manually enter my equipment, am I required to upload system specifications from a project site plan, or from a manufacturer spec sheet?
If the project’s inverter / modules are not listed in PowerClerk, applicants should upload system specifications from both the project site plan and from the manufacturer specification sheet.
How should two systems on the same parcel be named to differentiate the two?
Applicants should select a unique identifier for each system; there are no restrictions with regard to naming. In the application portal, you will also need to check the box for both as being “affiliated” with another application. For the first application completed, use the unique system name in the affiliated project number field since you won’t have it at that time. For the second application, input the actual project number from the first application in the affiliated project number field.
Will there be a way to specify in PowerClerk that I am expanding on an SREC II project and seeking to qualify that expansion for SMART?
Please note that in such situations, the SMART project must have its own dedicated generation production meter so rather than an “expansion”, this would be a new project at the same site. There is no need to specify in PowerClerk that the project is an “expansion”, as these types of projects are eligible under SMART. The Applicant would apply for the new project in SMART the way they would normally. If the Applicant wants to ensure the connection between the two systems is understood and eligible, they may upload a memo or other documents explaining the project as part of the online application.
Will customers be allowed to submit sensitive personal information (like SSN and tax documentation) to the portal?
Yes, CLEAResult is employing DocuSign to allow the customer to submit their SSN and e-signature on tax documentation to maintain privacy and confidentiality. The Applicant (typically the installer) will not be able to view the customer’s sensitive information, but will be notified when the documentation has been completed by the customer and they are able to move forward in the application process.
Is ACH information manually entered? Or will there be a similar DocuSign process?
The ACH process varies by EDC as follows:
Section C: SREC II/Prior Solar Program Questions
If a system is currently qualified under an older incentive program (SREC I, SREC II, Commonwealth Solar), can that system be expanded and qualified under the SMART program? If so, can both projects be behind the same meter?
Projects installed on the same parcel as an existing system that receives incentives are eligible to apply to the SMART program for another system at the same site. However, the new SMART system must be separately metered from the originally installed system. See also question B6 above.
Are projects under construction in the SREC II program with existing ISAs able to switch to the SMART program if they cannot be finished by the deadline? If yes, what is the process?
A project that is currently qualified under SREC II but is not operational may apply to the SMART program providing that all minimum eligibility requirements are met. Please note that these applications or program conversions will not be automatic. Every system wishing to participate in the SMART Program must submit a SMART Program application, and the project evaluation and assignment of capacity block reservations will be handled according to the SMART Program rules – typically on a first-come, first-served basis. A project that is qualified but not operational under SREC II that wishes to switch to SMART must do the following:
Upon the close of the SREC II Program on November 26, 2018, DOER will reject all SREC applications that are not operational or have not received an extension to become mechanically complete after November 26, 2018. Projects that are mechanically complete on or before November 26, 2018, must provide evidence to DOER by December 10, 2018 in order to remain qualified. However, if a project is still qualified for SREC II at the close of that program, but is not yet operational, the authorized representative must formally revoke the project from its SREC II status if they are planning on submitting an application for the same project under SMART.
Any project that is currently qualified and operational under an existing incentive program, such as the SREC I or SREC II program, is not eligible to apply to switch that system to SMART.
Can current completed projects that are interconnected, generating power and net metering but not in the SREC program, still apply for the SMART Program? If yes, what is the process for getting such existing or under construction projects into the SMART Program?
Yes, projects that have been authorized to interconnect, are not participating in SREC II, and which were completed on or after January 1, 2018, are eligible for the SMART program. These projects will need to apply for SMART incentives through the same process as any other eligible project. Projects larger than 25kW must have a fully executed ISA to apply for and receive a capacity block reservation under the SMART program. Applicants must also have site control and be in possession of all non-ministerial permits. Lastly, such projects will need to work with their EDC to obtain a revenue grade generation meter in order to begin receiving incentive payments under SMART.
Any project that is currently qualified and operational under an existing incentive program, such as the SREC I or SREC II program, is not eligible to apply to SMART.
Section D: Capacity Blocks
When will Block 1 close and the program base incentive levels transition to Block 2? If the Blocks fill quickly will they still decrease by 4%?
Scheduled reductions in the MA SMART program incentive rates are based on cumulative capacity of applications and not based on elapsed time. Within each EDC’s program allocations, Blocks will close and incentive rates will decline by 4% only when prior Block capacity allocations have been filled.
Please note that there are 5 utility areas/territories within the MA SMART program, and that each Block allocation will fill independently, based on applications specifically within that territory. As each EDC’s blocks are filled, the program will immediately start accepting applications for the subsequent block for that utility. The timing of each of these transitions will vary by utility and will be dependent upon the volume of applications received and how quickly each EDC’s Blocks fill. Also note that each Block has a minimum of 20% of the Block capacity carved-out, or set aside, for small systems ≤ 25kW, and a maximum of 35% of each Block allowed for these same systems. As such, the small system portion of each Block will fill independently of the large system portion, and this will also vary by EDC territory.
Is there a way to monitor where my application is in the review process or which block it may end up in?
DOER will post and regularly update the SMART Qualified Units list giving applicants an idea of where in the queue they fall. During the application process, the Applicant will be able to track an application’s progress in the PowerClerk portal.
At what point in the application process do I reserve my spot in a capacity block and secure my incentive rate?
Projects reserve their place in a capacity block and their SMART Incentive Payment Rate (SIPR) upon approval of their preliminary Statement of Qualification Application. If there are no changes to the project specifications or Adders during construction, the final SIPR will be the same as indicated on the Preliminary Statement of Qualification. However, if there are changes during construction, the final SMART Payment Compensation Rate may need to be adjusted and will be reviewed by DOER and finalized during Claim application approval process on the final Statement of Qualification.
As I understand it, systems greater than 1MW are not eligible to apply for Block 1 of the SMART Program, but rather must wait for Block 2. However, can we submit applications now for Block 2 in the portal? Or must we wait until Block 1 is completely closed first?
Systems equal to or greater than 1MW are eligible to receive Block 1 incentive compensation only if they are seeking a Compensation Rate Adder. Systems equal to or greater than 1MW that are not seeking an Adder were expected to apply during the competitive RFP process of Block 1. Therefore, systems of this size without any adders will only be eligible for Block 2 and beyond. As noted, we will not approve applications for Block 2 incentive levels within a particular EDC territory until the applicable Block 1 for that territory is filled. If any 1 MW – 5 MW projects without adders are received before the applicable Block 1 is filled, the SPA will put them in a holding queue.
In the Block 1 competitive RFP, projects that were selected but withdrew their application are not eligible to reapply under a capacity Block until 800 MW of other STGU have received a statement of qualification. Does that apply to projects that are accepted into capacity blocks going forward?
No, this potential restriction would only apply to projects that were selected during the Block 1 competitive solicitation but subsequently withdraw their applications.
The November 2017 Block 1 competitive RFP was requesting proposals for 100 MW of solar but less than this capacity was awarded. Does that mean that bids can be submitted for the remaining capacity at any time or at a specific time?
On January 11, 2018, 53.273 MW was awarded from the Block 1 competitive RFP statewide. The remaining unawarded capacity that was available during the RFP process remains within Block 1 and will be available on a first come-first served basis.
If a project with reserved capacity, drops out of the program (SQ expires), what happens to that capacity?
If a project that received its preliminary SQ fails to meet its Reservation Period or otherwise drops out of the program, the spoken for capacity will be added back to the Block in which projects are currently being qualified.
If a system files its claim application at a decreased AC capacity, what happens to that capacity?
The previously reserved but now unused capacity will be added to the Block in which projects are currently being qualified.
Section E: Documentation/Requirements Questions
The SMART regulations 225 CMR 20.06 specify a Customer Disclosure Form for community solar. When will projects applying for the Community Solar Adder need this documentation in place for the off-taker customers?
You can find the forms on the DOER website [HERE]. The Customer Disclosure Form will provide consumer information including, but not limited to, contract pricing for the length of the agreement, complete system cost information, operation and maintenance responsibilities, disposition of associated RECs and tariff terms, and anticipated production. The signed Customer Disclosure Forms for projects 25kW and less will need to be executed and submitted to the SPA along with the initial application. Community Solar Customer Disclosure Forms need to be completed and submitted at the time that the system is operational and enrolling in the tariff.
Will DOER release an example of “budgetary requirements” necessary to complete the Customer Disclosure form? Can you clarify this requirement?
DOER does not have specific guidance for this requirement, but there should be information about project budget provided to the customer that includes all project related costs so that the customer is aware of the total project costs that they will be paying.
What are the necessary qualifications that a Solar Tariff Generation Unity (“STGU”) owner must meet?
The SMART Program has developed an applicants’ checklist of required documents and has posted it on the MA SMART website HERE. Qualifications and documentation requirements will vary depending upon the size of the STGU applying for the incentive.
To be fully enrolled in the tariff and be eligible to receive the incentives, all systems must provide evidence of authorization to interconnect. For systems larger than 25 kW, this is required at the time of application; for smaller systems of 25 kW or less, this will be required at the project completion.
Finally, additional documentation may be required to claim the incentive at project completion, if applicable. This may include Schedule Z, Payment Credit Transfer Form, Renewable Energy Certificate Assignment and Aggregation Form, Customer Disclosure Forms, W-9, or ACH/EFT payment information.
Does the SMART incentive apply for sites served by a municipal electric utility? If so, what is the base incentive rate?
Projects interconnected to municipally owned electric utility/light department service territories are not eligible to participate in the SMART Program. Following the close of the SREC II Program, projects interconnected to municipal utility service territories may apply to the DOER for Class I Qualification. All interested projects should contact DOER for this process.
However, DOER has collaborated with representatives from municipal light plants (MLPs) to develop an incentive program separate from SMART. This program will primarily incentivize residential installations for facilities less than or equal to 25 kW DC. The program will be similar in structure to the Commonwealth Solar Rebate Program and will offer rebates to qualifying facilities. The Class 1 RECs generated by participating facilities will be transferred to the participating MLP in whose service territory the facility is located.
Will the funding from the MLP program come from ratepayers in the MLP’s district? What will the rebate be?
Funding for the MLP program will be a 50/50 match between ACP funds provided by DOER and the MLP in which the system in installed. More details about the exact rebate amount will be released soon.
Is the MLP program only for systems ≤ 25 kW?
Yes, the program is designed to incentivize small scale installations sized less than or equal to 25 kW DC in participating MLPs.
Will the Solar Land Use rules only apply to projects that are located on parcels with more than ten (10) contiguous acres of Chapter 61 land or former Chapter 61 land?
There is no minimum size or number of acres for these provisions to apply.
How will projects in the SMART program that are multi-family units work in terms of the Schedule Z allocations? Is using a Schedule Z still an option under SMART and if so, how will virtual net metering work under SMART?
Net metering rules and regulations have not been changed or impacted by SMART. All projects utilizing virtual net metering must continue to comply with those rules.
Do projects above 1 MW need a certification of Qualifying Facility (QF) from FERC, in addition to a Statement of Qualification Application (SQA) for RPS Class I RECs in MA?
As part of the application for the SQ, projects larger than or equal to 1 MW must document that they have filed a request with the Federal Energy Regulatory Commission (FERC) for certification of the proposed STGU as a QF, pursuant to 18 C.F.R. § 292.207. For systems less than 1 MW, they are not required to provide certification of QF status with FERC. Evidence of FERC registration for projects of 1 MW or larger will be required at the time of application. Self-certification will be accepted for all project sizes.
Regarding the contiguous parcels clause, if there are properties that are separated in a way that do not touch or share a common boundary, that are separated by one property, have separate interconnections, and in a legal sense are non-contiguous, how would these be viewed in the tariff?
Please refer to the SMART regulations 225 CMR 20.05 (5)(f) and (g). If all the requirements stated in the regulations are met, it is possible that these could be considered separate units.
Regarding the regulations and requirements for multiple projects owned by the same company, is there a requirement for minimum distance between 2 separate projects or any other restrictions in this regard?
Please refer to the SMART regulations 225 CMR 20.05 (5)(f) and (g). These are the sections titled Project Segmentation. There are no restrictions for a company to own multiple projects providing that they do not violate the Project Segmentation rules.
If a solar project that would be located on a building in a town that is served by an MLP, but which receives electric service/meter from one of the participating EDCs (Eversource, National Grid, or Unitil), would the PV project be eligible for SMART?
Yes, if this can be confirmed via a copy of a utility bill and authorization to interconnect from the applicable participating EDC.
If a project has a countersigned ISA with a different AC size than it is planning to qualify under SMART, does it need to get a revised countersigned ISA at the smaller size it plans to build at?
As far as the SMART Program is concerned, this is allowed. It is recommended that a note or memo of explanation be provided with the application to help prevent it being flagged or slowed down during the review process. However, you should confirm with the utility that the ISA is still valid for the smaller size. Whether or not you need a new ISA is ultimately up to the interconnecting utility.
Is there a definition for “mechanical completion” that the SMART program follows?
Mechanical completion means a Solar Tariff Generation Unit (STGU) that has been completely installed on the customer side of the meter, has passed the local wiring inspection, and is only waiting on the authorization to interconnect from the Distribution Company. To demonstrate mechanical completion, a STGU may provide a Certificate of Completion (COC), signed by the local electrical wiring inspector.
For the shading calculation done for Agricultural Solar Tariff Generation Units (ASTGU), is the 50% minimum reduction in solar based on time or energy? Is it that each square foot of land can’t be shaded more than 50% of the time or each square foot of land can’t lose more than 50% of the possible solar energy?
We recommend that you refer to the Guideline Regarding the Definition of Agricultural STGUs, specifically to page 3 in the System Design Parameters. These provisions are intended to ensure that crops can continue to be grown beneath the ASTGU. The MA Department of Agriculture and the MA DOER will require that applicants demonstrate that the sunlight available for crop production beneath, behind, and adjacent to the PV array is not reduced by more than 50% during the hours between 10AM and 5PM from March through October, and from 9AM to 6 PM from April through September. In other words, there can be no more than 50% more shadows on the field throughout the day, per square foot, because of the solar installation, than before the solar installation. Please find DOER’s ASTGU Shading Analysis tool, as well as information on how to use it and how to apply for this adder on DOER’s website HERE.
What contract documentation is provided to solar facilities that are awarded a SMART tariff rate?
The official award or notification document for the SMART Program is called the Statement of Qualification (SQ) which will be issued by MA DOER. Note that this is not a contract. The best description of that documentation and of the process is on the www.MASMARTSolar.com website in the Additional Resources section. Please see the SQ Reservation Period Guideline on the Resources tab of the webpage. Applicants will receive a preliminary SQ upon application approval, will have a 12 month Reservation Period to build the project, and will receive their final SQ upon completion based on the as-built specifications and proof of compliance with all regulatory requirements. The SQ will include the incentive rate that has been approved for the project. The legal or regulatory documents governing the program are the DOER regulations 225 CMR 20.00 and the company specific SMART tariffs to be approved by the MA Department of Public Utilities.
Does SMART have sunlight/shade requirements/minimums?
There are no minimum daylight or shade requirements in the SMART Program. As a performance based program that pays incentives based upon the kWh production, the intent is that this will move the market to self-select more optimal locations and orientations.
For systems over 25kW, evidence of site control is needed to apply for the SMART program. However, is there a length of time required for site control? Does one need to show 20 years of site control? I haven’t seen any mention of length of time.
An Applicant needs evidence that they have site control authorizing them to build within the 12 month Reservation Period. There is no specific requirement to show 10 or 20 years to match the term of the SMART incentive payments.
At what stage of the application process is tax paperwork collected? Whose social security number is recorded on the tax paperwork?
Tax forms will be collected during the Claim phase of the application, and tax ID information must be provided for the person or entity that will be receiving the incentive payment. When entering the tax ID information, it must exactly match the information on the W-9.
What is the timeline to complete the claim application?
Once a system has been issued an authorization to interconnect, the Applicant should submit the Claim as soon as possible, to enroll the project in the company specific tariff, and enable it to begin receiving incentive payments.
Can I update the System Owner information between submitting the preliminary application and when the claim application is filed?
Yes, a Change Request Form should be completed within the PowerClerk portal for changes of ownership up to and including the submission of the Claim. If there are ownership changes after the claim has been processed, those will be handled by the applicable EDC.
Am I permitted to change my technical specifications and design after submitting my preliminary application?
Yes, as long as the new AC size of the system is not larger than the AC capacity reserved initially (or, if larger, there is still remaining capacity in the same Capacity Block it was originally qualified under), and the change is made within the Reservation Period.
What equipment qualifies as used equipment? Transformers are often refurbished.
The question of used equipment only applies to the equipment used directly in the installation on the customer side of the meter and specifically applies to PV panels, inverters, energy storage systems, wiring, racking, and other equipment associated with the installation.
Can I apply to SMART with conditional approval from the utility?
Projects over 25 kW AC require fully executed ISAs to apply for the SMART program. Projects 25 kW and less are not required to have utility approval to install the facility at the time of application to SMART.
Are non-ministerial permits required to apply for SMART? Which permits and approvals are non-ministerial?
For systems over 25 kW, the documents referenced above, as applicable, and the following are required to apply to SMART:
Does the name on the utility bill and the uploaded contract need to be the same? Does this mean tenants are not eligible for the SMART incentive?
To facilitate review, it is preferable that the name on the uploaded contract matches the name on the utility account. However, this may not always be the case, and different household members may be represented on the two documents. If the names do not match, upload a simple cover sheet with the contract with an explanation (i.e. one spouse is on the bill, the other signed the contract, landlord signed the contract, but tenant’s name is on the utility bill, etc.) in order to prevent delays in processing the application or follow up questions.
Section F: Incentive Calculation and Compensation Questions
Based on 225 CMR 20.00 - Section 20.08, the Solar Incentive Payment is the (Base Compensation Rate + Compensation Rate Adders - Greenfield Subtractors) *kWh generated - value of the energy generated. I have two questions:
In the case of behind the meter systems, this energy value is derived from the avoided cost savings accrued by systems interconnected behind the meter. That is, behind the meter systems will serve on-site load first (and be compensated for this production in the form of avoided costs of energy they would otherwise have purchased from their EDC), before any export generation is sent back to the grid and compensated. This value of energy is removed from the SMART incentive calculation to avoid ‘double compensating’ system owners for the energy they produce. The SMART incentive is intended solely to provide incremental compensation to system owners for their STGU’s production. Whether through qualifying facility tariffs or net metering provisions, mechanisms already exist to compensate STGU owners for the value of the energy their systems produce and including these values in the SMART incentive would result in STGU owners being compensated twice for the same energy.
Regarding the second question, yes, standalone solar tariff generation units will receive value for the energy they produce, at the appropriate rate based on how the STGU is interconnected. This value will be conveyed either in the form of a direct payment if the system is interconnected as a Non-Net Metered Facility Qualifying Facility, or as a bill credit if the system is an Alternative Bill Credit Generation Unit or a Net Metered Generation Unit.
I am trying to calculate incentive kWh values. I understand how to calculate the base rate and adders, but I'm not sure what to subtract to get the overall incentive.
This is defined in the SMART Program regulation (225 CMR 20.00). Specifically, please refer to section 20.08 regarding calculation of incentive payments. As defined in the regulations, the energy value netted out of each STGU’s incentive value will depend on which type of STGU installed. In the case of standalone units, these value of energy variables will vary by EDC and by whether the standalone system is established as a Net Energy Metered system, an Alternative On-Bill Credit system, or a Qualifying Facility. Applicable values for each of these cases will be set by each EDC. Those values will vary by utility, rate class/code, and will change periodically over time.
In the case of behind-the-meter systems, the energy value netted out of the STGU’s incentive level is a three-year average of basic service, plus the current charges for distribution, transmission, and transition based on the utility rate class of the interconnected meter
How will consumers be compensated from the base compensation rates that resulted from the Block 1 competitive solicitation? Assuming there is excess production, will a check be cut from the utilities on a monthly or yearly basis or bill credit? What if they want to cash out?
The utilities will both make payments and provide bill credits, depending upon the nature of the compensation earned. Net metering values and QF energy payments will continue to be applied as under current mechanisms. SMART incentive payments will be made in the form of monthly payments from EDC’s to system owners.
Please note that system owners may not be paid up-front for the expected value of any incentive payments. Incentive payments will be calculated over time based on measured system production and will be paid to system owners as earned.
If a solar developer were to rent the roof of a commercial building and install a PV system, could that system be considered a standalone Solar Tariff Generation Unit?
If the Solar Tariff Generation Unit is not interconnected behind the utility meter of that building, but is interconnected in front of the meter, then yes, the incentives for this system could be calculated based on that STGU being a standalone system. This would need to be approved by the EDC and the building owner, and clearly demonstrated in the ISA and other application documents.
How does compensation work for a commercial rooftop facility that is not net-metered, and which does not have an off-taker for the energy. Under the SMART program, will the facility still receive the full compensation (base rate + adders)?
If a commercial rooftop is not interconnected behind the meter at the building, the system will be considered a standalone system, and the SMART incentive will be established at the base rate plus any applicable adders less the value of energy produced by the system. As a non-net-metered system, the system falls under the relevant EDC’s tariff for Qualifying Facilities (QF’s), and will be compensated for exported energy at the tariff’s QF rate. As noted in other questions regarding incentives, that energy value is then subtracted out from the SMART incentive rate (base + adders). The remaining value is what is paid to the generation unit owner by their EDC as the SMART incentive. Total system compensation would be based on both the value of the SMART incentive rate applied to all generated energy, plus the QF rate applied to all exported energy.
How does net metering impact the value of solar calculation for behind the meter systems? Can behind the meter projects participate in both programs?
The Massachusetts Net Metering program is a not changed by the implementation of the SMART program. Net Metering is regulated by the Department of Public Utilities. The value of energy calculated for behind the meter projects does not change. As a result, a behind the meter project may receive the SMART incentive and may also receive net metering credits. If a STGU is behind the meter, and is not able to receive net metering, then that system will receive wholesale rates, as a Qualifying Facility, for any net exported energy (i.e. system production above and beyond what is consumed on-site).
How are behind the meter PPA’s handled under the SMART program? Would all incentives be paid out to the customer directly, or would there be the option for the Third-Party owner to receive these payments instead? Do net metering or alternative on bill credits flow to the customer of record or the owner of the system? If the credits flow to the owner of the system is there still a value of energy adjustment?
All SMART incentives are paid to the STGU Owner, or to their designated Payee, directly based on the fixed rate established at the STGU’s qualification. The STGU Owner may or may not be the same person or entity as the utility customer. In the case of third party ownership models, the incentive will be paid to the third-party owner, not to the utility customer. The incentive does not consider any amount set forth in a PPA – PPA terms are determined between the system owner and the customer of record. If the system is classified as a Behind-the-Meter STGU, the value of energy calculation for that system will be set based on the three-year average of basic service and current transmission, transition and distribution charges tied to the utility rate of the meter the system is tied to. If the system is classified as a Standalone STGU, the value of energy will be equal to any bill credits generated.
Where will information be available regarding the 3-year average delivery and service rates needed to determine the ‘Value of Energy’ to subtract from base rates for behind the meter systems to determine the ‘all-in’ MA SMART incentive level for these systems?
The Behind the Meter Value of Energy Workbook is provided for informational purposes. DOER is working with the EDCs to gather information for rates that will apply for projects qualified in 2018 and 2019, and will post that information as soon as it is available on its website and at www.masmartsolar.com.
What is the difference between how behind the meter and standalone systems are compensated?
Standalone STGUs will receive value for the energy they produce, at the appropriate rate based on the nature of the STGU. This value will be conveyed either in the form of a direct payment if the system is interconnected as a Non-Net Metered Facility Qualifying Facility, or as a bill credit if the system is an Alternative OnBill Credit Generation Unit or a Net Metered Generation Unit. The value of the incentive payments to a Standalone STGU difference between the STGU’s value of energy and total compensation rate.
Behind-the-Meter STGUs receive a fixed incentive rate based on the one-time calculation at the time the STGU receives its preliminary Statement of Qualification. The fixed incentive rate will be in addition to any avoided electricity costs.
What are the tax implications for the SMART program? Can it be assumed that only the incentive portion beyond the avoided rate would be taxable? Are Alternative On-Bill Credits considered taxable?
Neither DOER nor CLEAResult nor the EDC’s can provide tax guidance - we advise all prospective program participants to consult qualified tax professionals with any questions related to the tax treatment of their STGU’s or the compensation they expect to receive from the output of these systems. The 1099 forms issued by the EDCs will be related to the incentive payments issued.
For a Behind-the-Meter STGU, can you confirm that the value of the energy subtracted does not include the supplier kWh charge?
The value of energy subtracted from the all-in compensation rate for behind the meter systems does not include supplier charges. The value is derived only from those charges stated in the regulation.
Are customers that purchase retail power from a retail energy supplier eligible for the SMART Program? If so, how would the value of energy be calculated for a BTM asset? Would it be the sum of the utility delivery charges (distribution, transmission, and transition) and the commodity price in the retail power contract? Or would you still use the utility basic service charges?
Yes, customers of retail electric suppliers are eligible for SMART. For a retail competitive supply customer, the value of energy for a BTMs system would use the applicable basic service rate for the investor owned utility service territory where they are located and interconnected.
Is there a projected timeline between submitting the claim application and receiving the initial incentive payments?
After submitting the Claim, it must be reviewed and approved. Upon approval, DOER will issue the final SQ. Per DPU 17-140-A HERE, the incentive payments will begin to be paid to the recipient within three billing cycles of claim application approval. Note that the approval requires evidence of the installation of the EDC provided generation production meter.
Will the first incentive payment from the utility be larger to compensate for the delay of three billing cycles? Will the payments eventually speed up? Is there a contingency plan in place to avoid lost incentive payments?
As specified in the DPU order, the initial incentive payment may take up to three billing cycles for set-up in the payment systems. Thus, in some cases, that initial payment will be in a larger amount to account for the actual amount of production during that set-up period. From that point onward, incentive payments will be delivered on a monthly basis.
Is there a cap on the size of Behind-The-Meter (BTM) solar projects? If the on-site load doesn’t need all the energy produced, would the system owner receive a cash payment for the energy plus the SMART incentive?
The only size cap that may apply to BTM systems is the limit of qualifying 5 MW AC per parcel under the SMART program. If a STGU has net energy exported to the grid, they will be compensated for the net export. The rate at which they are compensated will be either be the net metering credit rate (if they are able to obtain a net metering cap allocation), or they will be compensated at the rate subject to that utility’s Qualifying Facility (QF) rate. QF rates are based on ISO-NE clearing prices and fluctuate based on either monthly averages for ≤ 60 kW systems without interval metering in place or based on the hourly Locational Marginal Prices (LMPs) for larger systems with interval metering.
For a Standalone STGU registered as a State Qualifying Facility (QF), how will a project owner receive all the payments? Could both the incentive payments and QF compensation be paid directly to the project owner at the same monthly interval? Does there need to be any designated, commensurate electric load to take these payments directly?
For a Standalone QF, there does not need to be a significant on-site electric load or any behind the meter load in order to receive the payments. However, there does need to be an active account with the applicable EDC. The payment process for Standalone QFs will vary by EDC:
What happens if a behind the meter system over produces on a monthly or yearly schedule? Would the excess production roll over monthly? If there is excess credit at the end of a year, how is the excess kWh paid? Is it paid at the SMART tariff base compensation rate or is there no value to that excess?
Note that there is a difference between the value of the electricity vs. receiving SMART incentives. If the value of energy is being compensated through net metering, then the net metering rules will be applied. Net Metering is a standalone program that is separate from SMART and for which the rules established by the MA DPU have not been changed by the SMART Program. For the SMART Program incentives, a BTM facility is paid the approved incentive rate for whatever is generated as recorded on the utility owned generation production meter on the system. Thus, there is no such thing as “excess” production from the SMART Program perspective. These SMART incentives will be payments, not credits, for the entire 10 or 20 year term.
How often can the AOBC Payment Credit Transfer form be updated?
The AOBC Payment Credit Transfer form can be updated twice a year.
How will energy export compensation work for behind the meter systems?
The MA SMART program will not fundamentally change how distributed generation export compensation currently works under existing net metering and QF rules. These compensation mechanisms will continue to be a function of two criteria – first, whether or not a customer’s STGU is cap exempt or qualifies for a net metering cap allocation, and then, if it does not, whether or not the STGU’s nominal AC capacity is above or below 1 MW.
In the case of behind the meter STGU’s that receive a net metering cap allocation, regardless of system size, all net exports will be compensated at the applicable net metering credit.
Behind the meter STGUs that do not receive a net metering cap allocation will be compensated for net system exports per the terms of the relevant qualifying facility tariff with their EDC.
For STGU’s ≤ 1 MW, the system’s net generation and load will be aggregated over the course of a monthly billing period, and an average QF wholesale price for the prior calendar month will be multiplied against any summed exports to determine monthly QF compensation. STGUs 60 kW or less may choose the net metering method.
For STGU’s > 1 MW, export volumes will be calculated on an individual interval basis, and net exports during any interval will be compensated at a QF rate (not netted against aggregate net consumption over the course of that billing period). Customers receive specific hourly pricing for these exports equal to payments received by the Company from the ISO power exchange.
Is the BTM Value of Energy Workbook authoritative, or will the actual VOE be calculated separately on the back end? How often will the Workbook be updated?
The BTM Value of Energy Workbook is informational only at this time. The workbook will be updated once a year, and the rates applied to projects will change on January 1 of a new calendar year. The actual VOE will be calculated within the PowerClerk portal and approved by DOER before issuing the SQs.
What are the options for who/what entity receives the SMART incentives? Is the user of system output (the customer) the only option, or can another individual or entity be assigned the incentive payments?
When applying for a SMART Statement of Qualification, the Applicant will be asked to identify five parties:
These can be all the same person/entity, five different people/entities, or any combination in between. Typically, the System Owner will receive the incentive payments. However, at the project completion Claim phase, the Applicant will have the opportunity to name the Payee which can be a fifth party, or one of the other four.
If the Customer of Record is not the recipient of the incentive payment, will they be able to view the entire SMART incentive payment?
This may depend on the utility company. National Grid customers will see the incentive payments itemized on their utility bill, whether or not they are the recipient of the incentive payment. Eversource and Unitil Customers will not have the payment itemized on their bill.
Who do I notify if the incentive recipient changes? Is this the installer’s responsibility or the customer’s?
If the incentive recipient change occurs between Application and Claim, there is a Change Request form in PowerClerk that will allow that change to be recorded at or before the Claim is submitted. If the incentive recipient changes after the Claim and/or during the incentive payment term, the payee (recipient of the incentive) should contact the utility company directly with any changes to the recipient of the incentive or any changes to the method of distributing the payment, such as bank information.
For a project that is less than 25kW AC, is it permissible to construct a system that consists of both a ground mounted portion, and a roof mounted portion?
For STGUs that are ≤ 25 kW AC, a system that consists of both a ground mounted portion and a roof mounted portion behind-the-meter serving the customer’s load and which would be behind a single point of interconnection would be allowed in SMART and would be qualified using a single application. The compensation rate for systems 25kW and less are only determined by the base compensation rate, so they would be measured and valued as a single project.
Are there circumstances under which the Utility can terminate the SMART agreement with the Customer/Lessee?
Participants in the SMART program must remain compliant with all the terms and conditions set forth in the SMART regulations, 225 CMR 20.00, as well as the terms and conditions of the SMART tariff. DOER can suspend or terminate a Statement of Qualification if an STGU falls out of compliance with the SMART Program rules. Similarly, DOER can suspend or cancel certain Adders if the STGU falls out of compliance. If a utility determines that a System Owner or Authorized Representative has violated the terms and conditions of the tariff, they will report the non-compliance to DOER, and DOER may suspend or revoke the Statement of Qualification, which may lead to a suspension of incentive payments.
Is there a guarantee agreement with the Utility to make payments to the Lender/Bank/Lessor in the event of default by the system owner? (i.e. cessation of the business, bankruptcy, etc.)
There is no such guarantee. However, at any time during the term of the SMART program, a System Owner may re-assign payments to a new Payee. That new Payee could be the Lender/Bank/Lessor, etc.
What documentation will customers receive to use for financing?
The legal documents governing the rules of and participation in the program include the SMART Regulations (225 CMR 20.00) and associated DOER issued Guidelines, and the individual EDC SMART Tariffs. As for individual projects, the legal document that demonstrates their eligibility to participate in the program is the Statement of Qualification issued by DOER.
Who should I contact for a dispute with my incentive payment or meter reading?
All questions and concerns regarding meter readings and incentive payments should be directed to your respective utility.
Section G: Adders/Subtractor Questions
What are the documentation requirements to qualify for adders?
Please review the program Regulation (225 CMR 20.00) and Guidelines for adder specific requirements, which vary based on the adder. Also review the SQ Application and Claim Checklist HERE.
Can a standalone STGU be paired with storage and qualify for the energy storage adder?
Yes, however they must both be interconnected to the utility via the same point of common coupling. Please refer to the Energy Storage Guideline HERE.
Is there a time limit to apply for an adder after a preliminary SQ? Will I need to pay a second application fee to apply for an adder at a later date?
If the Adder is applied for after the preliminary SQ has been issued, the applicant will need to submit a Change Request form and pay the $70 Change Request fee. The value of such adders will be based on the adder tranche at the time the Change request is processed. After the Claim has been submitted and the final SQ has been issued, the only adders that can be applied for would be Energy Storage, Community Solar, or Low-Income Community Solar.
Based on the definition of “previously developed,” it is unclear why a project on a site with a house, driveway, established landscaping, a well, and other alterations to the landscape would not qualify as previously developed Category 1, non-agricultural. Is there a process to request reconsideration of these types of decisions?
The final determination of the Land Use category is made by DOER. The intent of the regulation is to provide a smaller incentive to projects that are proposed to be built on open, or “greenfield”, space. Acreage that is large enough for MW scale systems, but which only has one house is predominately open space. The intent of the previous development designation is for sites such as sand and gravel pits, former industrial sites, parking lots, or similar sites which were extensively developed in the past and have significantly altered landscapes. Lawns, pathways, and wells associated with a single house on a large property in and of themselves do not qualify as previously developed. You can request a reconsideration of the Land Use Category for the project by reaching out to the MA DOER at [email protected]
Are there any impacts on the SMART tariff if trees are cut?
There may be a reduction of the SMART tariff for clearcutting activities, depending on how the site is categorized for Land Use. Sites that are classified as Category 2 or Category 3 will be subject to the greenfield Subtractor. Commercial zoning is the primary differentiator between Category 2 (commercially zoned; not previously developed) and Category 3 (everything that is not Category 1 or 2). There are different greenfield Subtractor rates for Category 2 and 3.
If a canopy-like structure is built for an organization over an area that doesn't qualify for canopy adder (not parking, pedestrian, or canal), can it qualify for the building adder since it will serve as a roof for the activities under it?
If a project is not sited over a canal or a surface that is predominately used as a parking surface or pedestrian walkway, it would not qualify for the canopy adder.
Do you have any specific criteria to define areas that will qualify as pedestrian walkways that would qualify for the canopy adder? Would sites that have outdoor vendor events such as farmers markets or flea markets that are interested in a canopy structure over the area qualify as walkways?
Please refer to the definition of Canopy Solar Tariff Generation Unit in the 225 CMR 20.00 regulations; specifically, section 20.02. Pedestrian walkways must be regularly utilized by pedestrian traffic. Any application for the Canopy adder that does not clearly meet the intent of the regulations may need to be reviewed and pre-approved by DOER on a case by case basis.
If a solar PV system is sited on a closed landfill and the landfill land is owned by the municipality, and that project is selected in a SMART program block, is that project eligible for the landfill adder and public entity adder? Or is the public entity adder only if the municipality will be the off taker of the power?
As per 225 CMR 20.02, a Public Entity STGU must be owned or operated by the municipality or government entity, or the owner must assign 100% of the output of the system to the municipality or government entity to qualify for that adder.
If a large solar PV project is developed on a parking lot and the site is located on a capped landfill, can the canopy and landfill locational adders be combined for this project?
No. Only one adder from each adder category may be used for any given project. You can combine adders from different categories such as Location Based + Off-Taker Based, but not two or more within the same category on the same project.
Does each location-based adder have its own independent tranche? Or do all of the adders move collectively from tranche to tranche?
Yes, each Adder has its own tranche and they will fill and move independently.
Will it be possible to track the adder tranches as they fill up? Can an Applicant see their position in an adder tranche? And when is the position in the tranche secured? At the preliminary SQ or at the claim?
Yes, similar to the process of tracking block capacities, applicants will be able to track approved projects and projects in the queue applying for adders. CLEAResult will be updating these capacities on the PowerClerk portal homepage each business day. Applicants will be able to view individual project status on the portal. Adder tranche positions are secured with the preliminary SQ.
If a potential project has different solar arrays that each separately fulfill a different location-based adder, how would this be treated in the SMART Program?
Several standard exceptions to the project segmentation rules in 225 CMR 20.05(5)(f) are listed in 225 CMR 20.05(5)(g). What is described would qualify provided the facilities qualified for different adders and they are separately metered. So, while each of these sub- systems or configurations would be eligible to participate in MA SMART, each would require its own inverter and metering.
Additionally, in order to reflect the differential incentive rate that would be applied to each sub-system’s output, a separate MA SMART incentive application, which will ultimately result in a unique Statement of Qualifications from DOER, should be submitted for each sub-system.
Questions on how best to apply for and manage the interconnection of these systems to the electrical grid should be directed to the relevant EDC, based on the proposed location of your STGU.
To apply for an exception from the project segmentation rules other than those explicitly allowed under 225 CMR 20.05(5)(g), contact DOER at [email protected].
Would the construction of a 1.5 MW solar PV array on a municipal landfill that sells some of the energy to the municipality and the rest to community solar customers qualify to receive the Public Entity Adder? If so, what would the Community Solar customers receive? Would it be a blended rate?
To qualify for the Public Entity adder, the STGU must be located on public property and 100% of the energy generated must be provided to a public entity. In this case, the municipal landfill would likely qualify as public property, but the STGU could not provide some of the energy to the municipality and the rest to a community solar project to qualify for that adder. Only one off-taker based adder can be claimed per generation unit category on any given project. Public Entity and Community Solar are both off-taker based adders, so the STGU Owner would have to choose one.
To qualify for the Solar Tracking Adder, does 100% of the proposed installation have to be constructed utilizing a tracker racking system, or could the array qualify for the adder if say, only 60% was built using a single axis tracker (and the other 40% using a fixed-tilt system), because of land constraints?
The Solar Tracking Adder requires the use of a two-axis, or dual-axis, tracking system. See 225 CMR 20.07(4)(d):
Assuming that the facility used a two-axis array on 60% of the project and a fixed array on the remaining 40%, the SMART program would need to process those as 2 separate applications and each array may need to have its own generation production meter, depending on the EDC. They could both be interconnected behind the same point of common coupling and both be on the same ISA, but in order to qualify for the Solar Tracking Adder, that portion would need to have two-axis trackers and may need to be metered independently. The project may receive two separate SMART incentive payments, depending on the EDC, as these would be calculated at two different rates/kWh each month.
Section H: Community Solar Questions
Regarding institutional subscribers to community solar projects, under the Alternative On-Bill Credit (AOBC) system, if the anchor off-taker is currently in a 3rd party energy supply contract but still receives delivery from the distribution company in which the project is interconnected, can they use the on-bill credits? If so, does the credit get applied to their payment to the third-party supplier or just the delivery charges (T&D) from the utility? Does this depend upon whether the customer has a 3rd party supply contract with combined billing versus if the 3rd party supplier bills the customer separately?
It depends on the type of billing a customer utilizes with a retail supplier. If the customer’s supplier is using complete billing, the credits that are allocated are shared with the supplier portion of the bill. If the allocatee’s supplier opted for pass through billing the Company would only be able to apply credits to the distribution portion of the bill.
What is the definition of a "sufficient" subscriber base in order for an STGU to qualify for the Community Solar Adder?
A STGU seeking a Community Shared Solar adder, or a Low Income Community Shared Solar adder must show they meet the definition to qualify for the adder, and must demonstrate that no individual or distinct legal entity will receive bill credits or electricity in an amount that exceeds the applicable limits. For example, Community Shared Solar must have three or more Customers of Record and no more than two participants may receive bill credits in excess of those produced by 25 kW of nameplate AC capacity and the combined share of said participants capacity cannot exceed 50% of the total capacity of the STGU, except in cases of STGUs smaller than 100 kW AC. For Low Income Community Shared Solar, at least 50% of the energy output must be allocated to Low Income Customers. Documentation provided at the project completion phase must sufficiently demonstrate that these Program requirements have been met.
Upon interconnection and application for final enrollment in the tariff, the Community Solar Project must be at least 90% subscribed to be eligible to qualify for the adder.
When in the application process must STGUs demonstrate that they have a sufficient subscriber base to qualify for the Community Solar Adder?
There are two phases to the application process: Application and Claim. At the Application phase, the Applicant indicates their intention and plans for a Community Solar. If approved, the Applicant will receive a preliminary Statement of Qualification and will have a 12 month Reservation Period to complete their project. During the Reservation period, in addition to construction the STGU, the Applicant needs to finalize their off-taker subscribers and obtain the necessary signed Customer Disclosure and other forms. During the Claim phase, the Applicant submits copies of all the project completion documentation including the signed Customer Disclosure forms, Off-taker list, and other forms such as Schedule Z or Payment Credit Transfer forms to either the interconnecting utility and/or to the SPA. At the Claim phase, all the required off-taker subscribers should be signed up and documented. If these forms are not provided at Claim, the Applicant will not be eligible for the Adder.
If we qualify for a Community Solar project with three off-takers but one later drops out, what happens? Is there a penalty? If so, is there a grace period to sign up a new off-taker?
STGUs must be at least 90% subscribed in order to qualify for the Community Solar Adder, must provide new Community Solar Customer Disclosure Forms every year, and will be expected to be at least 90% enrolled at that time.
If the off-takers for a Community Solar project changes, can the project change to the Public Adder, or to Low-Income, or vice-versa if the remaining or new off-takers qualify for those Adders?
Yes, this is an allowed one time change during the Solar Tariff Generation Unit’s tariff term. Please submit a supplemental Change Request adder application and follow directions for this change request. When they do switch the adder rate available at that time will be applied.
Regarding the qualifications for the low income community solar adder, does the subscriber have to have an R-2 class or is it sufficient that they serve the low income community (mission, housing, etc.) despite not being listed as a Low Income Housing Authority?
here are three different types of low income designations in SMART and each has a slightly different requirement as evidence that they are eligible:
Low Income Community Shared Solar Operational ResultsUpdated Customer Disclosure Forms indicating Low Income rate codes and copies of electric utility bills showing the income eligible rate code must be submitted at the Claim phase when requesting the Final Statement of QualificationLow Income Eligible STGU (≤ 25 kW)Evidence that Customer of Record is classified as a Low Income Customer by the EDC will be confirmed via the income eligible rate code on the electric utility bill that must be submitted at the Application phaseLow Income Property STGU (> 25 kW)A Pre-determination letter from DOER submitted at the Application phase is the required back-up documentation for this Adder
What is described seems somewhere in the middle of the first and the third. So, if the off-taker is serving low-income customers but is not on a low income rate code, nor are they clearly a low-income entity such as a housing authority, you should get a pre-determination letter from DOER. Note that for Low Income Community Shared Solar, you won’t need that until the Claim (project completion) phase, but for the other two categories you will need it at the Application phase. To obtain a pre-determination letter from DOER, you can contact them at [email protected] .
Section I: Energy Storage Questions
How does the billing work and how is the storage adder applied to a project? How does this impact the project economics?
The Storage Adder rate is calculated using the formula presented in the Energy Storage Guideline. The rate is added to the base compensation rate for the solar tariff generation unit.
If I apply for a preliminary SQ with an energy storage system do I still need to pay the application fee twice?
No, applying for an adder during your initial application will not cause a second application fee or change order fee to be assessed.
If I decide to add energy storage to my project during my Reservation Period, do I receive a secondary Reservation Period to install my energy storage system and qualify for the adder?
Yes, you will be eligible for a 12 month reservation period for installing the battery, please see the Statement of Qualification Reservation Period Guideline HERE for further details.
For the Energy Storage Adder, the requirements are that the batteries need to cycle at least 52 times per year. Does the system owner handle the cycling of the battery? If not, who is controlling the storage system? Can the storage be controlled and used by the system owner to provide any additional grid services beyond the SMART Requirements? Or will it be controlled, or owned, by the utility?
Please see the Energy Storage Guideline HERE for further details on the operational requirements for the Energy Storage Adder. The System Owner will be responsible for the operation of the battery and ensuring it remains compliant with DOER’s Guideline.
Since the Energy Storage Adder is based on the kWh production, is this based on the total or gross PV production? Also, is the Adder applied to the entire amount or only to the battery discharge amounts?
The energy storage adder is applied to the total PV production that flows through the inverter and is measured by the EDC owned generation meter. The Energy Storage Adder is applied to the PV output.
For a project that was awarded through the Block 1 competitive RFP, is it possible to add energy storage to take advantage of the Energy Storage Adder (even though the award was just for base compensation solar)? If so what is the process and timelines?
No, the Block 1 competitive RFP was explicitly for projects not seeking adders. A project granted an award in the Block 1 Competitive RFP may not qualify for any adders under SMART.
Is it possible to add energy storage after receiving the Preliminary SQ? If so what needs to be done and does this change their qualification or place in the queue or block?
Yes, it is possible to add energy storage later in the process. The Applicant must submit a Change Request form for the Energy Storage via the online application portal. This will require a $70.00 change order fee, plus uploading any of the applicable forms and documentation required by the change. As long as the PV system size, schedule, and other characteristics are not changing, that project will not lose its place in the assigned Block. The Energy Storage adder however will be assigned a value from the available tranche at the time of the energy storage change order application.
Is it possible to add energy storage to existing solar projects from SREC II or earlier and apply for the energy storage adder through SMART?
No, the Energy Storage Adder is only available when combined with SMART solar projects.
When looking at potential PV Solar systems with energy storage, is it possible to apply if the battery cannot provide two hours of discharge at full capacity as required in the SMART regulations?
This issue was discussed by the Energy Storage Working Group and has been included in the Energy Storage Guideline published by DOER that can be found HERE.
Can a SMART STGU System Owner of a STGU that is already installed add a battery later (post-PV system completion) to that STGU system and qualify in SMART for the battery adder?
Yes, providing there is still funding available and all other SMART Program requirements are met. Such a project will need to submit a second application to the Program and obtain a Statement of Qualification for the battery system. The Battery Adder rate will be what is available at the time of the new, battery application and the incentive term of the battery will end concurrent with the original STGU term (after the original 10 or 20 years).
Regarding securing at storage adder for SMART application, in a situation where an applicant has a signed ISA for a PV system and the other requirements to submit a SMART application for the PV system, in order to apply for the storage adder, would the application also need a signed ISA for the storage system? Or would the applicant be able to apply for the storage adder while the storage system interconnection application is pending?
The determination of whether the storage system needs a separate ISA is up to the interconnecting EDC. If it is required and is completed and executed at the time of applying for the PV SQ, it can be combined on the same application. If not, it can be applied for at any time in the future via a separate application change order as noted in the answer to G - 3.
Assuming a 500kW solar system and 500 kW energy storage system (ESS), installed as a distribution level resource, that will also be used to bid into the wholesale market. The solar and battery systems will have their own metering but would be behind the meter at the point of interconnection. Is the correct way to calculate total kWh generated [SOLAR generation + BESS discharge - BESS charge] = Total kWh generated? Is it impacted if some of the kWh generated are bid into the wholesale market?
The SMART incentive would be based on the total kWh (AC) generated by the PV array times the approved SMART Incentive Payment Rate. Then amount of energy used to charge the battery, the amount of energy discharged by the battery, or any amounts bid into the wholesale market do not impact the amount of the SMART incentive payments.
Section J: Locations, Land Use and Project Segmentation
How is project segmentation applied on a property/parcel with multiple buildings?
The Project Segmentation rules in 225 CMR DOER regulations [20.05 (5) (f)] have several standard Exceptions in section [20.05 (5) (g)]and an Exception (8) which is for good cause.
Whichever Exception is the case, each system will require a separate application in the online portal and will receive its own Statement of Qualifications from MA DOER. During the application process you will be asked to identify whether a project is affiliated with another project and which Exception applies. Also, each system will need its own generation/production meter for reporting purposes. However, multiple systems can be on the same utility ISA and/or particularly for behind-the-meter (as opposed to standalone) systems, can be interconnected behind the same retail meter and delivery point.
If there are two projects qualifying for different adders on the same parcel, how are their compensation rates calculated?
If the projects meet one of the exceptions to the project segmentation rules and are allowed to qualify at the same time, the two systems must submit two separate but affiliated applications. Each project will be metered separately and have its total compensation rate calculated and applied independently with the applicable adder(s). However, if the two projects are standalone systems that are to be interconnected behind the same retail meter and delivery point in Eversource’s territory, the blended rate option is available due to Eversource’s current constraints for billing this configuration. If the two projects are behind-the-meter systems that are to be interconnected behind the same retail meter in National Grid’s territory, the blended rate option is also available on a case-by-case basis. The availability of the blended rate option, which is described in DOER’s Guideline on Establishing SMART Compensation Rates, is to be discussed with the EDC during the ISA process and its use requires DOER review and approval.
Can two systems on a single parcel be under the same ISA?
Yes, two systems on a single parcel can be on the same utility ISA. Particularly for behind-the-meter (as opposed to standalone) systems, they can also be interconnected behind the same retail meter and delivery point. However, the two systems must qualify for one or more of the Project Segmentation exceptions. We recommend reading over the Project Segmentation rule in 225 CMR section (20.05 (5) (g)) to ensure your project complies with one of the established Exceptions.
In the Land Use Guideline published by the DOER, the description of the requirements for Category 1 of Land Use, there is a case where the property is participating in the Chapter 61A tax incentive program. The Guideline establishes that if the parcel is part of this Chapter 61A program and had enrolled in it within the last 5 years, there are only specific types of projects that will be allowed to apply for the SMART program. Questions related to this are:
How would a scenario of multiple Canopy STGUs, each separately metered and on separate but contiguous parcels, be treated? I don’t see a specific exception that is spelled out which these projects might fall under.
Canopies are subject to the project segmentation rules. Unless the installation of a canopy meets the current established exemption of allowing a canopy on the same parcel as a building mounted project or a ground mounted project, the applicant must submit a good cause exemption request to the DOER at [email protected] for review and determination.
Regarding 225 CMR 20.05 section (5) subsection (f) on project segmentation, how would that apply to five parcels of land that have good adjoining space for solar. Would this regulation allow for a standalone system to be built with 7 sub arrays trenched to the new service?
Project Segmentation rules also have some standard exceptions. Exception 20.05 (5) (g) (5) could apply in this case as long as the 7 sub arrays are interconnected behind a single point of interconnection, and you get an approved ISA from the utility for that interconnection.
Section K: Miscellaneous Questions
Are there any webinars or meetings set up anytime soon that we can attend?
DOER hosted a webinar along with the EDCs and CLEAResult to demonstrate how to use the SMART application portal. A recording of this webinar and the SMART Program Launch presentation slide deck is available on DOER’s website HERE.
DOER also hosted a webinar along with MDAR and BlueWave to demonstrate how to use the ASTGU Shading Analysis tool. A recording of this webinar is available on DOER’s website HERE.
How does one sign up to receive DOER email updates related to RFP’s and general program information issued by DOER? Put another way, where is the sign-up for DOER’s mailing list?
Sign up through this link email list to get on the DOER email list. You should request to be on the “Solar PV contact list”.
Is it possible to be an owner of a system for this program if you have no prior experience with solar? If a building owner wants to have complete ownership of a PV system and participate in the SMART program, could they do so?
There are no restrictions on who owns the PV system. That said, the SMART Program is designed for experienced, highly qualified solar developers. It is highly recommended that an owner with little or no solar experience hire or partner with an experienced, highly qualified solar developer.
Would DOER consider granting a good cause extension for legal issues that prevent an STGU awarded under the SMART Procurement from meeting the 12-month construction deadline? For example, if the project was appealed by abutters after submission of the project application to the SMART Program, would that qualify as a good cause for an extension?
The 12-month construction deadline ‘clock’ doesn’t start until the Statement of Qualifications is issued and/or the official SMART Program Effective Date, whichever comes later.
Once the clock starts, awarded bidders may request an extension if there is such a legal challenge ongoing that may delay the project. Please refer to the Statement of Qualification Reservation Period Guideline HERE for more information. The situation described above would appear to meet the legal requirements for such an extension, but DOER can’t officially make a determination and/or extend such an extension until the deadline is established and, an awarded bidder makes a formal extension request.
Do you have a list of everyone/all projects who bid in the initial solicitation?
The submissions to the Block 1 competitive RFP were confidential. However, the selected bidders have been publicly announced. That information is available at www.masmartsolar.com.
What is the procedure for minor changes in DC capacity after a Statement of Qualification has been issued? Often module availability is different at the construction phase than what was planned during the design phase.
Minor or de minimis changes to the DC capacity are allowed as long as the AC output does not increase beyond what was approved for the Statement of Qualifications. A change that would increase the AC output would disqualify the project from the SMART Program and/or would require withdrawal and re-application for the new, larger system size. Reductions in AC size and/or minor changes in the DC capacity of the panels can be recorded in the PowerClerk system upon project completion.
Are there any warranty requirements under the SMART Program such as workmanship, inverter and/or PV panel minimum warranties that must be given to customers from their contractor, installer, or developer?
There are no warranty requirements to qualify for SMART. However, on the Customer Disclosure forms for third party and direct owned small systems, it is required that the customer be informed of the contact for ongoing system maintenance.
Are there any prevailing wage or labor rate requirements for projects awarded an incentive under the SMART program?
The SMART Program does not have any such specific requirements. However, if the Applicant or Host site is subject to such requirements, participation in the SMART Program does not necessarily waive or remove those requirements.
Under the SMART program final regulations, does it matter what voltage a stand-alone solar facility connects to? For example, could a project connect to a 69kV or 115kV line owned by one of the EDCs and still be eligible to participate in SMART so long as the project is within that EDC service territory? Or is it necessary to connect to a distribution level voltage, and how would that voltage level be defined?
SMART Program supported systems must interconnect to distribution lines that are owned and operated by one of the eligible EDCs, are within existing service territories of the EDCs as of January 1, 2018 and serve retail electric loads. Standalone systems may interconnect to a 69kV or less line as long as it is part of the distribution system that is regulated by Massachusetts regulators and serve retail electric loads. However, direct interconnection to transmission lines that are regulated by FERC is not allowed within the SMART Program regardless of the voltage of the transmission line.
If our application is approved to construct a large PV system for the SMART program, are there any clauses in the agreement or rules in the program that would prevent investors to obtain Investment Tax Credits (ITC)?
We are unable to provide information about qualifying for the federal tax credit. Applicants should speak with a tax professional or directly with the Internal Revenue Service which handles the ITC. That said, there are no references, controls, or rules regarding the ITC in the SMART program rules, nor is the potential qualification for the ITC considered in any way during the application review process for the SMART Program.
Does the program require third-party reporters or authorized data providers to submit monthly production reports? If so, are you able to provide information on how to apply? Is there a set of requirements for the type of hardware used in collecting data? Is there an application process for having hardware approved for the SMART program? What data needs to be submitted, and how often?
The SMART Program does not require third-party reporters - responsibility for metering, recording and reporting STGU production in the SMART program lies with the utilities. The EDCs will be making the purchasing and specification decisions and will be installing the revenue grade meters themselves or via their own selected sub-contractors. Participation in the SMART program will require that installers provide the necessary wiring and meter sockets necessary to support the utility installation of these utility owned-operated generation meters, however, and applicants whose system configurations require the installation of utility generation meter(s) for MA SMART purposes will be assessed fees by their EDC for the installation of this (these) meter(s).
Once an STGU is enrolled in the MA SMART program, the STGU owner will have no ongoing STGU production data reporting obligations during the term of the SMART tariff – these requirements will be managed by the relevant EDC metering the output of those systems.
Do you know if SMART projects will appear in the Class-I Qualified Units List? Or will the SMART SQA (or equivalent) be the only place these projects are listed? For entities that track and forecast Class-I Generation, how can they be assured that they won’t be double counting when SMART qualifications start coming in.
MA DOER will post a separate SMART qualified units list on their website.
Are AOBC credits transferrable between Eversource East and West?
No. Customers in the Eastern Massachusetts (EMA) and Western Massachusetts (WMA) territories continue to be supported by entirely separate billing systems and Eversource will not process Alternative On-Bill credit transfers between the two territories as this time. However, Alternative On Bill Credits may transferred across ISO-NE load zones within EMA.
Will the portal remain open while the 400 MW review is being conducted? How long will this review process take?
Yes, the portal will remain open during the 400 MW review, and preliminary SQs will continue to be used. DOER expects the 400 MW review to take several months.
Will the SMART factor be included in the Renewable Energy Charge on customer bills? Will it apply to non-solar customers?
No, the SMART factor will be a separate and distinct line item on customer bills and will apply to all ratepayers within a utility’s service territory.
How long will the SMART factor be on customer bills?
The SMART factor will be on customer bills for the duration of the program.