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Massachusetts Sets Energy Storage Target

On June 30, 2017, the Massachusetts Department of Energy Resources (DOER) announced that Massachusetts would adopt an aspirational 200 megawatt-hour (MWh) energy storage target to be achieved by January 1, 2020. The target is the second largest in the nation, although it is far lower than California’s 1.3 gigawatt storage mandate. Still, Massachusetts’ storage target will make the commonwealth a leader in the burgeoning energy storage field.

The process of setting storage targets began last summer, when Massachusetts enacted a law directing DOER to determine whether to set targets for electric companies to procure energy storage systems by January 1, 2020. In September 2016, Massachusetts released a report called the “State of Charge,” which recommended the installation of 600 megawatts (MW) of energy storage by 2025. The report predicted that 600 MW of storage could capture $800 million in system benefits to Massachusetts ratepayers. The energy storage industry praised the 600 MW level as a good starting point.

DOER’s “aspirational” 200 MWh by 2020 target falls short of the “State of Charge” recommendation, but leaves the door open to achieving 600 MW by 2025. DOER’s letter announcing the target noted that “[s]torage procured under this target will serve as a crucial demonstration phase” for Massachusetts to gain knowledge and experience with storage. “Based on lessons learned from this initial target,” the letter continues, “DOER may determine whether to set additional procurement targets beyond January 1, 2020.”

Beyond DOER’s storage target, Massachusetts has a broader Energy Storage Initiative, which includes a $10 million grant program aimed at piloting energy storage use cases and business models in order to increase commercialization and deployment of storage technologies. DOER also announced that it will examine the benefits of amending the Alternative Portfolio Standards, an incentive program for installing alternative energy systems, to expand the eligibility of energy storage technologies able to participate. While Massachusetts’ storage targets are not as lofty as some in the industry were hoping, the commonwealth is demonstrating a clear commitment to developing its energy storage industry beyond the few megawatts currently installed.




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Massachusetts Legislation Spurs Offshore Wind Power Development

On August 8, 2016, Massachusetts Governor Charlie Baker signed into law a major energy bill aimed at putting Massachusetts at the forefront of states developing offshore wind power. The law, An Act Relative to Energy Diversity (H. 4568), requires Massachusetts electricity distribution companies to procure 1,600 megawatts (MW) of offshore wind energy by June 30, 2027. The United States currently has no offshore wind generation, but Rhode Island wind developer Deepwater Wind is nearing completion of a 30 MW offshore wind farm, which will be the first of its kind in the country. In a statement, Governor Baker’s office said the bill “spurs the development of an emerging offshore wind industry…and represent[s] the largest commitment by any state in the nation to offshore wind.”

The new law requires Massachusetts distribution companies and the Department of Energy Resources (DOER) to jointly develop a competitive bidding process for offshore wind energy generation resources by June 30, 2017. The bidding process will be subject to review by the Massachusetts Department of Public Utilities (DPU). The law permits one solicitation or multiple staggered rounds of solicitation that must result in at least 1,600 MW of aggregate nameplate capacity of offshore wind energy. If the solicitation is staggered, each round must seek proposals for at least 400 MW of capacity, and the costs in each subsequent round must decrease or the proposal will be rejected by the DPU. All proposals received during the solicitation process are subject to review by DOER.

Each distribution company will enter into a contract with the solicitation’s winning bidders for the distribution company’s apportioned market share, calculated based on the total energy demand for all distribution companies, compared to demand in an individual distribution company’s service territory. Distribution companies may use the long-term contracts to purchase renewable energy certificates, energy, or a combination. All proposed long-term contracts executed with distribution companies will be filed with the DPU and subject to DPU approval. Specifics on the solicitation, contracting, and approval processes will come when the DPU and DOER promulgate regulations carrying out the new legislative mandate for offshore wind.

The legislation represents a new chapter in offshore wind for Massachusetts. The infamous Cape Wind project—a proposed 468 MW wind farm—has been held up in the planning stages for years and its current status is uncertain. The new law is a definite step towards Massachusetts’ development of offshore wind energy generation resources. Several wind development companies already hold leases in Massachusetts waters.




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Massachusetts DOER Releases Solar Carve-Out II Guideline

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.




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Massachusetts DOER Proposes to Expand to 1600 MW Generation Eligible to Create SRECs

The Massachusetts Department of Energy Resources (DOER) earlier this year released its proposal for the Commonwealth’s next solar energy incentive program, the Solar Carve-Out II program (SREC II).  The program will increase to 1600 MW the amount of solar generation in Massachusetts qualified to produce solar renewable energy certificates (SRECs), well above the 400 MW cap set by the existing and now-over-subscribed first Solar Carve-Out program.  DOER is hosting a public hearing on the proposed regulations and is accepting written comments until January 29.

The SREC II proposal includes many of the same mechanics as DOER’s first Solar Carve-Out program.  Qualified renewable generation units will produce SRECs for 40 calendar quarters that may be sold or deposited into an auction account for bidding.  The auction price, which sets a price floor, will initially be fixed at $300 per SREC, the same auction price that currently exists under the first Solar Carve-Out program.  The SREC II auction price will decrease in subsequent years beginning in 2017.

One new aspect of SREC II is the segmentation of generation units into four market sectors, with each sector receiving its own SREC Factor (which determines the number of SRECs per MWh of electricity generated by a generation unit):

  • Market Sector A: any Generation Unit with a capacity less than or equal to 25kW, Solar Parking Canopy Generation Units, Emergency Power Generation Units or Community Shared Solar Generation Units.  Proposed SREC Factor:  1.0
  • Market Sector B: any Building Mounted Generation Unit, or ground mounted Generation Units with a capacity of greater than 25 kW for which 67 percent or more of its annual electric output is used on-site.  Proposed SREC Factor: 0.9
  • Market Sector C: any Generation Unit with 50 percent or more of the equipment used for generating power installed at an Eligible Landfill or Brownfield and any Generation Unit with a nameplate capacity less than or equal to 500 kW for which less than 67 percent of annual electrical output is used on-site.  Proposed SREC Factor: 0.8
  • Managed Growth Sector: any units that do not meet the requirements for the other market sectors.  Proposed SREC Factor: 0.7

The SREC Factor is designed to create an incentive to develop smaller solar generation units and a greater variety of generation units.  DOER plans to review SREC Factors in early 2016 with any changes applying to generation units qualified on or after January 1, 2017.

The Managed Growth Sector is subject to an annual capacity cap.  Each year, DOER will prescribe an annual capacity block to be filled by qualified generation units in the Managed Growth Sector.  DOER’s proposed annual capacity block for 2014 is 26 MW, and for 2015 the capacity block is 80 MW.  DOER will announce the annual capacity blocks two years in advance for future years.




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