November 26th was a big day for solar energy in Massachusetts. As promised, the Massachusetts Department of Energy Resources (“DOER”) opened the application portal for the long-anticipated SMART Program. Applications received between November 26th and November 30th will be considered to have been received at the same time. Starting on December 1st, applications will be reviewed on a first come, first served, basis.
Also on November 26th, the Massachusetts Department of Public Utilities approved a model tariff to implement the SMART Program. The Massachusetts electric distribution companies now have until December 3rd to file company-specific tariffs, which should be a formality. A few days earlier, on November 23rd, the Department cleared up some lingering issues relating to the SMART tariff, clarifying the process for setting application fees (which will be overseen by both DOER and the Department), allowing the capacity blocks and compensation rates for the former NSTAR and WMECo service territories to remain separate (but with instructions to combine them by January of 2020), and confirming that the distribution companies cannot register certain solar facilities in the wholesale energy market as settlement only generators (at least until a forthcoming decision addresses issues related to solar participation in capacity markets more generally).
A lot of people have been waiting for and working towards this date for a long time. The authorizing legislation for the SMART Program was signed in April of 2016. DOER has been working with stakeholders to design and refine a post-SREC program for at least that long, as documented in gory detail on DOER’s website.
Like many new regulatory programs, the SMART Program can seem complex. And it can be frustrating to participants when there is no past experience to use as a guide for program implementation. But there is excitement about SMART for good reason. The big question now is how quickly the 1,600 MW of the SMART Program will fill up, especially the capacity available in the National Grid territory. The 400 MW threshold for a DOER review of the program is likely to be reached quickly.
Another issue to watch is what types of solar facilities are developed. The SMART Program was designed to support a diverse array of different solar facilities, including community shared solar, qualifying facilities, solar + storage, low-income solar, and agricultural solar. In part, the SMART Program uses differentiated compensation to achieve that goal. Now that the program is open, it will be interesting to see what types of facilities are actually developed.