Massachusetts DOER Releases Draft Guidelines for New Near-Term Resource Multiplier for Clean Peak Energy Standard, Comments Due by September 13th
This is the seventh blog in our “2024 Clean Peak Standard” blog series. Read the first six blogs here.
On August 23, 2024, the Department of Energy Resources (DOER) published a draft of the Near-Term Resource Multiplier Guideline. As covered in our prior Blog Post of the emergency regulations, eligible resources will receive a multiplier value of 2, applicable for 10 years from the effective date of their Clean Peak Resource qualification. This multiplier is limited to 50 MW of total capacity, though the regulations note that “after notice and opportunity for public comment, [DOER] may increase this cap in the future.” During the Public Hearing held in August 26th stakeholders encouraged DOER to expand the capacity limit and open or create a similar multiplier to Front of the Meter (FTM) projects.
Below we summarize the guideline presented by DOER:
Eligibility Criteria
To qualify for the Near-Term Resource Multiplier, a Clean Peak Resource must meet the following criteria:
- It must be connected to the distribution system.
- It must be a standalone, front-of-the-meter Qualified Energy Storage System (QESS), not co-located with a Qualified RPS Resource OR a Demand Response Resource.
- The resource must not have received a Statement of Qualification on or before January 1, 2025, and must commence commercial operation before January 1, 2027.
- The resource cannot also receive the Distribution Circuit Multiplier.
- The cumulative capacity qualifying under this program for any single entity cannot exceed 50% of the total capacity designated by DOER, initially set at 50 MW.
Application Process
- Applicants must submit a reservation application with specific details such as ownership information, an executed Interconnection Service Agreement (ISA), and other required permits.
- A Statement of Qualification Application (SQA) is not initially required but must be submitted within 18 months of reservation approval or by January 31, 2027, whichever comes first.
- DOER will sequence initial reservations based on the ISA execution date and subsequently approve them on a first-come, first-served basis.
Implications
While 50 MW seems like a very limited amount of capacity (and, it is), for reasons discussed in our September 9, 2024 Market Module briefing, even small amounts of additional supply can have significant impacts on CPEC pricing. Furthermore, as discussed above, the regulations leave open the potential for an increase in the 50 MW cap. Our analysis of the EDCs’ storage interconnection data shows that there certainly is enough pending projects to fill the 50 MW many times over, though the time to complete interconnection (studies and associated upgrades) as well as the charging limitations being applied to many distribution-connected storage projects create significant challenges to projects that may wish to take advantage of the new multiplier. To learn more about the Clean Peak Market Outlook service, and to access our more detailed analysis of this multiplier and its impacts on the overall market, please reach out to the Clean Peak Market Outlook team.
Next Steps
We don’t expect DOER to make any major changes soon to the regulations posted, they are seeking comments from stakeholders.
Stakeholders that couldn’t provide feedback on this guideline at the Clean Peak Energy Standard Emergency Rulemaking Public Hearing held on August 26 may provide written comments to DOER and those should be sent to [email protected] by Friday, September 13, 2024 at 5:00 P.M. EDT.
DOER still plans to conduct a comprehensive review of the CPS, where more changes might be introduced. More information on the Program review may be found on the 2024 CPS Programmatic Review website.
