September 13, 2011

Massachusetts continues to raise the bar for net metering and interconnection

As previously reported, the Massachusetts Department of Public Utilities (DPU) has been working to facilitate certain aspects of the net metering and interconnection process for the state’s distributed generation customers. In 2010, legislation was enacted that requires the Department to adopt rules and regulations necessary to implement certain changes to net metering, including the adoption…

As previously reported, the Massachusetts Department of Public Utilities (DPU) has been working to facilitate certain aspects of the net metering and interconnection process for the state’s distributed generation customers. In 2010, legislation was enacted that requires the Department to adopt rules and regulations necessary to implement certain changes to net metering, including the adoption of a system that provides proposed facilities with an assurance of net metering eligibility (which also has been referred to as a net metering queue). On September 13, 2011, the DPU issued an order detailing a proposed system of assurance of net metering eligibility. Given that there is a statutory cap on net metering capacity, assurance of net metering eligibility (termed a Cap Allocation in the proposal) would provide adequate certainty for host customers that they will be able to net meter when they are ready to interconnect their facilities.

According to the proposal, each business day, a process administrator (chosen by the DPU) will calculate the remaining available capacity under each of the public (for government facilities) and private (for commercial and residential) caps for each distribution company as the difference between: (1) the capacity of the applicable cap; and (2) the sum of: (a) the aggregate capacity of all host customers receiving net metering services, as reported by each distribution company each day; (b) the capacity of host customers that have been granted a cap allocation; and (c) for the private cap only, the 10% of the available capacity reserved for host customers with small class I net metering facilities.  The administrator will make this information available on the internet.

A few notes from the proposal:

  • The proposed system is a voluntary process available to all host customers and it is not a prerequisite to net meter.
  • A host customer may lose a cap allocation or place on the waiting list if it fails to meet applicable deadlines, makes any major changes to the facility plan (solar to wind, public to private cap change, etc…) or submits an application that contains material misrepresentations.
  • To calculate capacity, a solar net metering facility’s capacity will be 80% of the Facility’s direct current rating at standard test conditions, and all other Facilities will be the alternating current nameplate rating.
  • As net metering capacity becomes available (e.g., as a result of an increase to a Distribution Company’s peak load, loss of a cap allocation, legislative changes, etc.), a process administrator can offer it to host customers on the applicable waiting list, in order of priority.

On August 18, the Massachusetts DOER also issued a lengthy distributed generation study that it had commissioned to improve the interconnection process.  Some of the more important findings triggered recommendations such as:

  • Revise the tariff to mandate the creation of a uniform on-line interconnection application system;
  • Require the utilities to establish transparent criteria for what triggers the requirement of various system upgrades paid for by interconnecting customers, and a formal process by which the utilities update the criteria;
  • Hire at DPU an ombudsperson who will hear and quickly resolve interconnection disputes between developers and utilities;
  • Require the utilities to increase collection of certain interconnection project tracking data; and
  • Revise the tariff to require utilities to address area networks.

Thanks for doing all this ground-breaking work, Massachusetts. All of this work is sure to pay off in leaps and bounds for the renewable energy industry.