May 29, 2020
ESA Recommends Improvements to Massachusetts’ SMART Program to Drive Energy Storage Integration
ESA submits comments today to the Massachusetts Department of Energy Resources (DOER) on emergency regulations (225 CMR 20.00) issued on April 14, 2020 to update the Solar Massachusetts Renewable Target (“SMART”) program. In our comments, ESA recommends that the DOER eliminate the continued phase down of the incentive adder for energy storage in the program expansion; expand opportunities for longer duration energy storage systems to be eligible for the energy storage adder in the program expansion; and modify proposed land-use prohibitions to avoid inhibiting the development of larger-scale solar projects required to integrate energy storage systems.
Additionally, ESA expresses support for the DOER’s requirement that new solar projects of 500 kW or greater install energy storage for SMART program eligibility, and recommends that the DOER allow this requirement to be met through not only onsite co-location, but also through operational or contractual pairing with a non-co-located energy storage resource.