ESA Comments on SMART Program Emergency Regulation

Posted: July 11, 2017 - 16:55 / Massachusetts / ESA Filings
Dear Commissioner Judson:
On behalf of the Energy Storage Association (“ESA”), please accept these Comments in response to the Massachusetts Department of Energy Resources’ (“DOER”) request for comments in the above-referenced matter. ESA appreciates the opportunity to provide comments on the “225 CMR 20.00 – SMART Program Emergency Regulation.” We commend the DOER for its rigorous engagement with the storage and developer community in the development of these regulations, and we recognize that these regulations incorporate much of the feedback that was provided to the DOER.
For the reasons explained below, ESA respectfully requests that DOER modify the proposed regulations by (1) exempting the storage adder from the draft regulation’s proposal to cap adders (Section 20.07(5)); and (2) revising the definition of Energy Storage System (Section 20.02).
See the full letter here.