Department of Energy Resources (DOER) has officially opened up a rule-making
process to amend its Renewable Energy Portfolio Standard (RPS) regulation after
signaling its intent to "tweak" the current SREC formula late last
year. These proposed changes are now officially open for public comment and
DOER will hold a public hearing on March 22 at the State House (Gardner
Auditorium) at 1:00 pm. Written comments may also be submitted until 5:00
pm on March 25, 2013.
The DOER’s proposed
draft regulation amends the Solar Carve-Out Program in a number of ways but
some of the more critical items include:
- Making adjustments to the SREC’s Minimum Standard
Formula by removing the subtraction of Alternative Compliance Payment
(ACP) Volume from the Compliance Obligation, allowing for more growth.
DOER will recalculate the CY2013 Compliance Obligation to reflect this
- Allowing any owner of SRECs, not just the project owner
or operator of the solar generation unit, to deposit into the Auction
- Clarifying that Re-minted SRECs may not be deposited
into the Auction Account in subsequent years.
- Establishing an Assurance of Qualification process
to" queue up" Statement of Qualification Applications (SQAs) as
we get closer to the 400 MW cap. DOER will also develop a Guideline to
provide additional details. Special accommodations will be made for
- Specifying that Assurances of Qualification shall be
granted (securing your system’s spot in the 400 MW cap) if your SQA
provides either an approval to interconnect from the utility or (in lieu
of such approval) evidence of:
- Fully executed Interconnection Services Agreement
- Adequate site control
- All necessary entitlements, but NOT final permits such
as building and electrical permits
Note: The criteria
above are almost identical to the Net Metering System of Assurance.
- Providing project owners with flexibility by allowing
them to get their Statement of Qualification (SQ) any time from the point
at which they receive their Assurance of Qualification until commercial
operation. This assists owners trying to maximize their Opt-In Terms with
their construction timelines. The draft regulation contemplates the
development of a process for project owners to lose their SQ if they fail
to meet certain requirements.
- Modifying how the Solar Carve-Out Program will continue
once the 400 MW cap is reached, as well as making accommodations for
Competitive Suppliers for CY2013. In addition, DOER addressed a couple of
non-solar related items, such as increasing the size of eligible hydro in
response to legislative amendments and allowing eligible biogas to utilize
common carrier pipelines to transport gas to generation units to create
RECs. Previously, this option had been available only to landfill gas.
Click here for details on
the regulation with the proposed changes and more information on the public
hearing. If you have any questions, comments, or suggestions, we encourage you
to consider participating in the public comment or hearing process.
If you have any
questions or would like additional information about the RPS regulation, the
public comment and hearing process, or want to learn more about renewable energy and energy efficiency
regulations and programs, please contact Craig M. Tateronis, at 617 456
8021 or email@example.com.