On June 20, 2025, the Massachusetts Department of Energy
Resources ("DOER") filed emergency regulations for the SMART 3.0 Program, the newest iteration of
DOER's Solar Massachusetts Renewable Target ("SMART")
tariff-based incentive program supporting the development of solar
in Massachusetts. The new regulations introduce sweeping changes to
the existing regulatory framework, including replacing the
declining block model with an annual adjustable block and rate
structure, establishing new rules intended to increase access for
low-income individuals and properties, implementing annual
compliance reporting and enforcement action provisions, and more.
Stay tuned for future posts describing the key changes to the SMART
Program in more detail.
DOER also filed minor revisions to the existing regulation, 225 CMR 20.00, to accommodate for the program
transition and create an end date for eligibility under the current
program.
- DOER will stop accepting Statement of Qualification Applications under the prior regulation on December 31, 2026; solar projects wishing to qualify after that date must apply to be qualified under the new regulations at 225 CMR 28.00.
- To have an application considered under the existing regulations, a project must demonstrate that on-site physical work of a significant nature (i.e., continuous installation of racks or other structures to affix photovoltaic ("PV") panels, collectors, or solar cells to a site) has begun prior to December 31, 2025.
- Certain projects that have not begun significant construction by December 31, 2025 may still be approved by DOER to submit an application under the existing regulations, so long as a project demonstrates "significant investment in the development process" prior to December 31, 2025 and that it would not meet the eligibility criteria of 225 CMR 28.00. DOER will review and approve such applications on a case-by-case basis. "Significant investment in the development process" can be shown through documentation such as Interconnection Service Agreement payments, interconnection study payments, or equipment procurement.
The emergency regulations are already in effect, but DOER is
accepting public comments and may make revisions in response to
feedback during the three-month rulemaking period. Written
comments are due by 5:00pm on July 25, 2025. Three public hearings, two virtual and one
in-person at a to-be-determined location in western Massachusetts,
will be held by DOER on July 24 and 25.
DOER has requested that stakeholders submit public comments as soon
as possible, given the emergency filing and expedited rulemaking
schedule. Watch this space for more details on how the SMART 3.0
Program may impact Massachusetts solar development.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
