SMART Program

SMART Massachusetts Solar Program

What is SMART?

SMART stands for the Solar Massachusetts Renewable Target program. It is a program run by the Department of Energy Resources (DOER) to incentivize and support the development of solar renewable energy in the state of Massachusetts. Eligible utility companies pay a tariff-based incentive to the system owner if their SMART application is approved by the solar program administrator and DOER. Eligible utility companies include Eversource, National Grid, and Unitil. 

SMART has been in operation since 2018 but recently, on July 10, 2024, DOER announced a straw proposal in order to improve the program. This 2024 straw proposal is the first step in starting a discussion around changes DOER plans to implement. DOER wants to incorporate stakeholder feedback and comments into legislation to better prioritize low and moderate income rate payers to aid in the development of clean solar energy. They also emphasized that this straw proposal will continue to reflect their five guiding principles: equity, consumer protection, transparency, coordination, and simplicity. 

Draft regulations based on the responses to the straw proposal will be released in the Fall of 2024.

Steps leading up to the SMART straw proposal:

1. 9 topic-specific stakeholder working sessions
2. Independent economic analysis*
3. Targeted stakeholder consultations4. Straw Proposal
*conducted by Sustainable Energy Advantage, LLC (Analysis 1 and Analysis 2)

What’s changing with the 2024 Proposal?

  • There will no longer pre-determined capacity blocks with declining base compensation rates → Annual adjustable block and rate structures will be implemented.
    • Adjustments will be based on a predetermined cost model customized for MA solar economics (rates can go up or down depending on market conditions and progress towards solar targets)
    • Incentive rate adders will be subject to adjustment as well
    • DOER will re-evaluare solar costs yearly with individual consultation.
  • Previously the SMART program had a limited solar capacity of 3,200 MW that was divided among the 3 utility companies aligned with SMART. Depending on what utility service territory you are in and how many customers are served by said company, your capacity limit would change. Each utility company would then divide their capacity into different categories, which are known as “capacity blocks”. With this new 2024 straw proposal, small projects (<25 kW, mostly residential) will no longer be subject to said capacity allocations and DOER will not limit the amount of capacity that can be qualified
    • Small projects no longer need to submit a preliminary statement of qualification (PSQ)
  • Large projects (>25 kw) will be determined annually based on progress towards solar deployment targets and real-time solar costs
    • To start off the project capacity blocks for 2025-2026 and 2026-2027 have already been set to 300 MW
    • Capacity will be allocated across service areas proportional to load
  • Small projects will receive a fixed SMART incentive payment (SIP) over their SMART tariff term
    • SIP will be set annually as part of the annual cost analysis
    • Will never be set below $0.01/kwh
    • Low-income projects will receive an adder on the annual fixed SIP
  • Increase in adder values and additional adders being included
  • Revising eligibility requirements for projects qualifying for the public entity adder to include a right to construct 
  • Small projects will no longer be eligible to receive the energy storage adder. The concept behind this is to steer smaller projects to Clean Peak Standard and Connected Solutions programs. Previous SMART programs have not aligned well with those programs, incentivizing back-up storage more than supplying grid energy to address peak.
    • Increasing project size required for energy storage system adder from 500 kw to 1 MW
  • Energy storage system must be online and able to discharge 85% of the time during the summer months and in the winter months or must participate in a demand response program for the solar tariff generation unit to continue to be eligible for the energy storage adder
    • The energy storage system must reach, at a minimum, 156 cycles annually for the solar tariff generation unit to continue to be eligible for the energy storage adder
  • Projects will no longer be viewed on a parcel by parcel basis but rather the project footprint itself for existing land use categorizations 
  • Ground mounted projects > 250kW AC on important agricultural farmland or undeveloped land that do not qualify for a locational adder will receive the greenfield subtractor
    • All projects will receive flat subtractor rate of $0.06/kWh plus acreage based subtractor 0f $0.04/acre impacted by the footprint
    • Any ground mounted project subject to greenfield subtractor or qualifying for the agricultural adder will pay an additional one-time application fee to hire an environmental monitor 
  • When maintaining vegetative cover to prevent soil erosion applicants must use plantings of native species appropriate to the geographic area
  • Establish new $0.06/kWh adder for applications that conduct proactive community engagement (only available to those receiving the greenfield subtractor)
  • Expanding eligibility for newly created farmland in order to expand land access for new or underserved farmers
    • All land intended to become newly created farmland will become eligible farmland if the applicant has demonstrated the pre-existence or viability of agricultural production
    • Applicants will need to submit a farm business plan to show agricultural viability to qualify for the agricultural solar tariff generation unit (ASTGU)
  • Expanding flexibility on panel height requirements for tracking ASTGUs (minimum height is being lowered from 10 to 8 feet)
  • Clarifying eligibility for requesting an exception to maximum sunlight reduction requirements 
  • New proposed definitions for terms “newly propose”, “comparable crops”, and “low income solar tariff generation unit”
  • Considering use of photosynthetic active radiation (PAR) values instead of sunlight reduction % for determining project eligibility
    • *additional stakeholder conversations are needed for this proposal specifically
  • No longer separate adders and eligibility criteria for community shared solar and low-income community shared solar
  • Guaranteed meaningful benefits to community shared solar (CSS) customers
  • Improve program administration and billing processes to improve customer experience 
  • Allows low-income customers to qualify based on participation in other need-based programs or through self-attestation of income eligibility
  • Expand low income property definition to include additional types of housing/facilities servicing low-income residents
  • Adjustments to consumer protection by making customers aware of the language used in direct ownership, third party, and community solar agreements
    • Providing more guidance on what they should look for when making decisions regarding solar power development 
  • Improvements of program implementation including development of educational materials

*Projects that haven’t already received a SMART qualification will be eligible to apply under the updated program. Any project pending or approved application will be subject to the predecessor regulations.

How can you learn more & contribute?

  • Watch the July 10, 2024 webinar outlining the proposal
  • Read the Straw Proposal with Clarifications released July 29, 2024 
  • Department of Energy Resources will post regular updates on their website
  • Draft regulations will be released Fall 2024 

In the Media:

Links to Resources: