Earlier this week, the Massachusetts Department of Energy Resources (DOER) finalized the details of the Solar Carve-out II extension, which seeks to facilitate the transition between that program and DOER's proposed Solar Massachusetts Renewable Target (SMART) program. The extension program helps bridge the gap between the Solar Carve-out II incentive program, which went into effect in April 2014 and was designed to support the market until 1,600 MW of PV capacity had been installed, and the SMART program, which DOER had earlier announced will not become effective until, at the earliest, January 2018. The details of the extension announced in the March 21 Guideline suggest the gap between the programs may be longer than originally anticipated.

As Adam Wade described in an earlier post on the details of the SMART program and DOER's transition plan, Solar Carve-out II projects greater than 25kW that have not met other extension program deadlines can still seek an SREC II extension by resubmitting a Statement of Qualification Application and demonstrating "good cause." The March 21 SREC Factor Guideline affirms the following reduced SREC Factors for any project that: (1) has not already received an extension prior to the effective date of the guideline (2) is mechanically complete or authorized to interconnect by March 31, 2018, and (3) receives a good cause extension:

Market Sector                          SREC Factor
A                                                0.70
B                                                0.60
C                                                0.55
Managed Growth                       0.50

Facilities that are mechanically complete or commercially operational after March 31, 2018 but before the effective date of the SMART program will be granted the following reduced SREC Factors until the effective date of that program:

Market Sector                          SREC Factor
A                                                0.65
B                                                0.55
C                                                0.50
Managed Growth                       0.45

DOER reserved the right to further lower the SREC Factors noted above if the SMART program does not become effective by July 1, 2018.

The agency had announced in previous drafts of the Guideline the reduced SREC factors for (1) projects less than 25kW authorized to connect after January 8, 2017, and (2) projects greater than 25kW that received an extension by spending at least 50% of their total construction costs by January 8, 2017 and satisfying other regulatory requirements.

We will provide updates on the development of the SMART program as they become available.

To view Foley Hoag's Energy & Cleantech Counsel blog please click here

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.