Massachusetts' Department of Energy Resources (DOER) has proposed a 0 MW 2016 annual capacity target for the sector that features traditional ground-mounted solar PV projects larger than 650 kW and not sited on landfills or brownfields.
Under the state's new solar renewable energy credit program (SREC II), projects are broken into four sectors, with varying degrees of preference given to small generation, community solar, building-mounted solar, self-consumption projects, and projects on landfills and brownfields.
PV projects which do not fall into any of these other three categories, are larger than 650 kW and feature less than 2/3 of electricity used for an on-site load fall into the “Managed Growth” portion of the program.
DOER proposes to allocate no capacity for this sector in 2016, and as a result new projects would not be eligible for SRECs. Borrego Solar VP of Strategy and Business Development Dan Berwick notes that due to a backlog of 109 MW, this will effectively put an end to new projects in this sector.
“It is shifting us, it is going to force (the solar industry) into those sectors,” notes Berwick, who also serves as chair of the Massachusetts chapter of Solar Energy Industries Association (SEIA). “(The Managed Growth) segment is done, we aren't doing that anymore.”
A letter from SEIA, the New England Clean Energy Center (NECEC) and Solar Energy Business Association of New England (SEBANE) spells out the consequences of a zero allocation. The document warns of “the end of an important market sector, a further erosion of confidence in the Massachusetts solar market, millions of lost development dollars that were invested in anticipation of a more pragmatic estimate, and job contraction”.
The proposed zero allocation is based upon DOER's future market estimates in the other three sectors, in order to meet state targets to install roughly 150-200 MW annually towards Massachusetts Governor Deval Patrick's goal of 1.6 GW of installed solar PV by 2020.
SEIA, NECEC and SEBANE have appealed DOER's findings, stating that they are based on overly optimistic estimates of growth in the other sectors. The three organizations cite multiple factors, including pending net metering caps, which could provide barriers to growth in the other sectors.
SEIA, NECEC and SEBANE estimate that the Managed Growth sector could accommodate 50 MW of PV in 2016, given more conservative assumptions. All three organizations also backed a bill to remove net metering caps as part of an overall policy redesign in the state's last legislative session, however this did not make it to a vote.
While Berwick notes that there is a “legitimate public policy objective here that DOER is pursuing”, he also says that it will affect the participation of larger developers in the state's market.
“It has an impact on how attractive Massachusetts looks to us,” notes Berwick. He also emphasizes that the allocation is not yet final.