The Massachusetts Department of Energy Resources (DOER) released a draft guideline last week outlining a proposed process to grant Assurances of Qualification to solar generation facilities seeking to participate in the Solar Carve-Out II program. The guideline is designed to mirror the Massachusetts Department of Public Utilities’ Net Metering System of Assurances since many solar projects seek to qualify for both net metering and the Solar Carve-Out II program.
A solar generation unit must receive a Statement of Qualification (SQ) from DOER to take part in the Solar Carve-Out II program. To receive a SQ, the generation unit must have approval to interconnect with the grid from the local distribution company and meet certain other qualifying criteria. Because interconnection occurs at a late stage in project development, DOER is developing the Assurance of Qualification program to establish a process for solar generation units to reserve a spot in the queue and have some assurance, prior to incurring the significant costs of development, that the project will be able to participate in the Solar Carve-Out II program (so long as it meets the Assurance of Qualification conditions). The Assurance of Qualification is particularly relevant for projects that will fall under the Managed Growth Market Sector since there is likely to be more capacity proposed for development than is reserved under the limited Annual Capacity Blocks, as set out in the current draft of the Solar Carve-Out II regulations.
To obtain an Assurance of Qualification, a generation unit must submit (1) a Statement of Qualification Application, (2) an executed Interconnection Service Agreement, (3) evidence of adequate site control and (4) all necessary governmental permits and approvals to construct the project. If there is insufficient capacity available under the applicable Annual Capacity Block, DOER will place the generation unit on a waiting list until more capacity becomes available. Once an Assurance of Qualification is received, the unit has nine months to receive approval to interconnect. The guidelines provide two limited circumstances under which this reservation period may be extended: (a) six months where a legal challenge to a permit or government approval remains pending and (b) indefinitely where the unit is only waiting for the distribution company to approve interconnection.
DOER is accepting comments on the draft guideline through March 28, 2014.