Representative Thomas Golden
Representative Patricia Haddad
Representative Brad Jones
Senator Michael Barrett
Senator Marc Pacheco
Senator Patrick O’Connor
Conference Committee on H. 4756 & S. 2608
State House, Boston

Dear Chairman Golden, Chairman Barrett, and Conference Committee Members,

On behalf of the cities and towns of the Commonwealth, the Massachusetts Municipal Association is writing to offer comments on H. 4756 & S. 2608, An Act to Increase Renewable Energy and Reduce High-Cost Peak Hours. Clean and renewable energy is very important to cities and towns in Massachusetts and we look forward to working with you to continue to make the Commonwealth a leader in clean energy development, and to ensure that renewable energy is feasible for our cities and towns.

Nearly every city and town in Massachusetts now has a solar development, 210 municipalities have been designated as Green Communities, and over 68% of Massachusetts residents live in a Green Community. Cities and towns have helped the Commonwealth to exceed its solar goal of 1600 megawatts, far ahead of the 2020 schedule. The MMA supports efforts to develop a balanced, long-term energy plan with a range of renewable energy sources to ensure a sustainable energy supply for residents, businesses and communities. Many provisions in these bills before this committee are in line with the MMA’s policy positions on renewable energy, energy efficiency and climate change.

The MMA appreciates the opportunity to provide comments on the following provisions:

Net Metering
The MMA strongly supports the elimination of the net metering cap to allow municipal solar projects to go forward with more certainty. Section 42 of the Senate bill would eliminate the net metering cap for both public and private projects. Net metering is a critical part of solardevelopment financing. When the cap is reached in a service area, cities and towns often have projects in the queue that are unable to move forward. This uncertainty over net metering can cause delays in planning projects and can prevent municipalities from taking advantage of solar development opportunities. Lifting the net metering cap is essential, and will allow for more long-term planning to enable municipalities to participate in solar projects.

Monthly Minimum Reliability Contribution
A recent decision by the Department of Public Utilities allows Eversource to impose new charges on net metering customers and has set a precedent for other utility companies to attempt to move forward with similar charges. This has made the future of solar less feasible for communities. Under the DPU’s ruling, Eversource will be able to impose a new “monthly minimum reliability contribution” (MMRC) on net metering customers who come online after Dec. 31, 2018. The impact will vary by project, but could make it more difficult for communities to benefit from net metering. We support the provisions in the Senate legislation that would help to protect municipalities from these additional charges. The Senate bill would delay implementation of the MMRC and constrain efforts by utilities to implement such a charge by requiring that a demand charge be based on demand during peak hours and requiring that a demand charge may only be assessed if metering equipment is available to customers so that they can track their electricity usage in real time.

The MMA has supported a statutory exemption from the MMRC for municipal and community solar customers. The possibility of changes in solar financing, such as changes through rate restructuring, the addition of MMRCs for solar projects, and a decrease in incentives for communities, could all lead to increased costs for municipal customers, which would ultimately fall on local taxpayers in the form of higher property taxes or reduced services (education, public safety or public works, e.g.) elsewhere in the budget. We urge the committee to consider the impact that these changes would have on a community’s ability to use net metering to move forward with renewable energy projects, and on the Commonwealth’s position as a leader in solar and renewable energy.

Thank you for the opportunity to provide input on this important legislation. We appreciate your commitment to bringing clean and renewable energy to the Commonwealth and protecting ratepayers from increased costs. If you have any questions, please do not hesitate to have your staff contact me or MMA Legislative Analyst Victoria Sclafani at 617-426-7272, ext. 161 at any time.

Sincerely,

Geoffrey C. Beckwith
Executive Director & CEO