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Net Metering Frequently Asked Questions and Answers

Net Meter

Net Meter
DPU's Net Metering Frequently Asked Questions and Answers

Net Metering Frequently Asked Questions and Answers

1. What is net metering?
   • Net metering allows customers of certain electric distribution companies to generate their own electricity in order to offset their electricity usage (check whether your distribution company is listed below).  All customer classes are eligible for net metering.  Common examples of net metering installations include solar panels on a home or a wind turbine at a school.  These installations are connected to a meter, which will measure the net quantity of electricity that the customer uses (“retail meter”).  The retail meter spins forward when the customer uses electricity from the distribution company, and it spins backward when the customer generates excess electricity (thereby “exporting” electricity to the electric grid).  A special retail meter (also called the “net meter”) is required to allow for the “netting” of usage and generation, especially when there may be exporting of electricity.
     
2. Why would I want to get involved in net metering?
   • Net metering can lower a customer’s electricity bill by reducing the amount of electricity that the customer buys from the distribution company. Net metering allows customers to receive credits for excess electricity generated by a net metering facility but do not use. Some customers get involved in net metering because of an interest in the environment and renewable energy.
     
3. What types of generating facilities are eligible for net metering?
   • To qualify for net metering, you may install any type of generating facility as long as it is smaller than 60 kilowatts (“kW”). G.L. c. 164, § 138 ; 220 C.M.R. § 18.00.  If the generating facility uses wind, solar, anaerobic digestion, or renewable energy at a farm, it may be up to and including 2 megawatts (“MW”) (or up to 10 MW for a public facility) and still qualify for net metering. G.L. c. 164, § 138 .
     
4.  How long has net metering been available?
   • Net metering has been available to customers in Massachusetts since the 1980s.  In 2008, legislation was enacted that: (1) increased the allowable capacity (or size) of net metering facilities that use renewable resources to create energy from 60 kW to 2 MW; (2) increased the value of the credits for electricity generated by these facilities from the wholesale rate to nearly the retail rate; and (3) allowed net metering customers to allocate net metering credits.  St. 2008, c. 169, s. 78. Additional legislation was passed in 2010, 2012, 2014, and 2016, which further modified net metering in Massachusetts, most notably raising the overall amount of allowed net metering projects.  St. 2010, c. 359, s. 25‑20 ; St. 2012, c. 209, ss. 23‑30 ; St. 2014, c. 251 ; St. 2016, c. 75 .  The 2016 legislation amended the net metering laws by: (a) directing distribution companies to calculate Market Net Metering Credits after a specified time frame; (b) updating the net metering capacity limits; and (c) defining the process for distribution companies to submit proposals for adding a monthly minimum reliability contribution to electric bills for customers receiving net metering credits.
     
5.  Does the Commonwealth regulate net metering?
   • Yes, the Department of Public Utilities (“Department”) has a set of regulations, to govern net metering in Massachusetts. 220 C.M.R. 18.00. These regulations carry out state law requirements.  Also, the Department addresses questions and issues raised by the public in Department proceedings. and engages in informal problem‑solving with the electric distribution companies and net metering customers.
     
6. Why are there different caps?  How much net metering is allowed in Massachusetts?
   • State law requires each distribution company to maintain separate net metering caps for public and private net metering facilities.  St. 2010, c. 359, s. 29.00. Each cap is equal to a percentage of each company’s highest historical peak load, which is the most electricity consumed by the distribution company’s customers at any one time. Effective April 11, 2016, the caps are:

Private Net Metering Cap (7%)

• Once an electric distribution company fills its net metering caps, it can no longer allow customers to take service under its net metering tariff. Note that cap exempt facilities (cap exempt facilities are those with a nameplate rating less than ten kilowatts on a single-phase circuit or 25 kilowatts on a three-phase circuit) will be able to net meter even if the caps are full. See 220 C.M.R. §§ 18.02, 18.07(5). and below for more information.

1. What is a net metering tariff?
   • Like many other electric tariffs, the net metering tariff is a schedule of the rates, charges, terms and conditions that electric distribution companies must follow when providing net metering or other distribution services to customers.  Stated another way, the net metering tariff specifies the way in which an electric distribution company must treat a net metering customer.
     
2. Where can I find my company’s net metering tariffs?
   • The links provided are NOT the official version of each company’s tariff. While reasonable efforts have been made to ensure the accuracy of the data provided, do not rely on this information without first checking the official edition of the tariff, which is available on each distribution companies’ website and from the Department’s Secretary Mark Marini .
     • National Grid net metering tariff
     • NSTAR d/b/a Eversource Energy net metering tariff
     • Western Massachusetts Electric Company d/b/a Eversource Energy net metering tariff
     • Unitil net metering tariff

1.  What must I do to be eligible for net metering?
   • You must be a customer of certain Massachusetts electric distribution companies;
   • You must meet all of your electric distribution company’s requirements before you interconnect your generating facility; and
   • You must receive a cap allocation for your net metering facility if it is larger than 10 kW on a single phase circuit or larger than 25 kW on a three phase circuit.  See below for more information on cap allocations.
     
2. Am I eligible to receive net metering services if I am using a Competitive Electric Supplier ("CES")? 
   • A customer that uses a CES is eligible to receive net metering services.  It is important to keep in mind however that all net metering rules and regulations still apply.  For more information, please visit the Legislation and Regulations webpage .  Furthermore, please keep these additional important rules in mind.
   • Depending on whether a net metering customer using a CES receives one combined bill or separate bills, certain portions of the electricity bill can be offset by net metering credits:
     1. If a customer receives combined billing (meaning a CES bills a customer through the distribution company), net metering credits can be applied to the entire electricity bill including the supply portion of the bill.
     2. If a customer does not receive combined billing (i.e. the customer receives at least two bills, one from the distribution company and one from the CES), the net metering credits can only be used to offset the bill from the distribution company.
   • The net metering credit will be based on the distribution company’s basic service charge (not the supply charge of the CES).  For example, if distribution company X is charging 7 cents per kilowatt hour for basic service, but the net metering facility or customer is paying the CES 6 cents per kilowatt hour, the credit component is still 7 cents.
     
3. May I net meter only a portion of a generating facility?
   • No. A customer may not receive net metering services for a portion of a generating facility. D.P.U. 11‑11‑E  at 19. 
     
4. May I receive net metering services if I already have generating equipment on the same parcel of land?
   • Maybe. However, it is not possible to have more than one net metering facility on a single parcel of land unless a formal exception is granted by the Department. 
   • If your existing generating equipment is receiving net metering services, it may be possible to expand your facility.  Also, your net metering facility may be installed in phases. D.P.U. 11‑11‑E  at 19.However, if you seek to expand your net metering system the value of your net metering credits may change.  D.P.U. 16-64-C at 25-29.  
   •  If your net metering facility contains existing and new generating equipment, the facility will be classified (i.e.. Class I, II, or III) on the basis of the total generating capacity. D.P.U. 11‑11‑E  at 18, n.14.
   • If your existing generating equipment is not a net metering facility, it is possible to install a new net metering facility on the same parcel of land, provided that the facilities are wholly separate from each other (see below).
     
5. Am I eligible to receive net metering services if there is already an existing qualifying facility (“QF”) on the same parcel of land?
   • Yes, but the QF and the net metering facility must be wholly separate from each other. The QF and the net metering facility cannot share an interconnection point or a meter. D.P.U. 11‑11‑E  at 19, n. 15.
     
6. Is net metering available to systems owned by a third party (i.e. not the Host Customer and not the interconnecting Utility) and subject to a power purchase agreement (“PPA”) or other agreement?
   • Yes. The PPA, lease, net metering purchase agreement, or other agreement will often determine how the Host Customer assigns net metering credits, but systems subject to such agreements are not prohibited from net metering.
   • For more information on net metering under a PPA in the public cap, the DOER published a Renewable Energy Power Purchase and Net Metering Credit Purchase Agreement Guidance for State Entities.    
     
7. Are there any applicants that are forbidden from receiving net metering services?
   • Yes, a net metering facility or net metering customer may not be: an electric utility, generation company, aggregator, supplier, energy marketer or energy broker. G.L. c. 164, § 139(2)(e) .
     
8. If I am a customer of a municipal electric company, may I get involved in net metering?
   • Maybe, but the rules could be quite different for municipal electric companies since they are not obligated to adopt the net metering rules issued by the Department and implemented by the investor-owned utilities. Contact your municipal electric company to find out whether it offers net metering.

1. What is a "Host Customer"?
   • The Host Customer is a customer with a Class I, II, or III net metering facility that generates electricity on the customer’s side of the meter. 220 C.M.R. § 18.02 .  In other words, the Host Customer is the customer of record with the electric distribution company and the person or entity whose name appears on the account of a net metering facility.  A simple way to determine the customer of record for a specific account is to identify the recipient of electric bills from the electric distribution company.  The Host Customer is important because the Host Customer decides what happens to any allocated compensation for excess generation (such as net metering credits).  Note that each net metering facility can only have one Host Customer.
     
2. Must I buy and/or own the generating facilities that I install?
   • No.  Under the net metering regulation, 220 C.M.R. § 18.09(5). generating facilities can be owned and/or financed by someone other than the Host Customer.
3. Can a group of people pool money and buy a generating facility together?
   • Yes, but one person must be designated the Host Customer.
4. If I consume 100% of my electricity on site and never plan on exporting electricity to the grid, do I need to register with the System of Assurance as a net metering facility?
   • No. You do not need to register with the System of Assurance if you are offsetting your load on site and never plan on exporting electricity to the grid.

1. What is the electric grid?
   • The electric grid is the system of electric distribution lines that electric distribution companies use to deliver electricity to their customers.  If a Host Customer generates excess electricity, it is exported to the electric grid.
     
2. Who decides whether and how my generating facility may interconnect with the electric grid?
   • Your electric distribution company.  For more information on interconnection, please contact your electric distribution company directly, or visit the following webpages for more information:
     • National Grid interconnection information
     • NSTAR d/b/a Eversource Energy interconnection information
     • Western Massachusetts Electric Company d/b/a Eversource Energy interconnection information
     • Unitil interconnection information
     • Massachusetts Distributed Generation and Interconnection
       
3. Must I install a net metering facility behind an existing retail meter?
   • No, you may pick a place where there is not currently a meter, but the net metering facility must be connected to the electric grid through a retail meter.  Without a meter, it would be impossible to measure and record electricity that you consume or export.
     
4. What does it cost to connect a generating facility to the electric grid?
   • It depends.  The cost to interconnect generating facilities is highly dependent on several variables, including: (a) the size of the generating facility; (b) the proposed location of the generating facility; and (c) the amount of electricity that could be exported to the electric grid.  The electric distribution company needs detailed information to determine the total interconnection cost.  Accordingly, there is no universal standard by which to calculate interconnection costs; each situation is unique.
     
5. Where would I buy equipment for net metering?
   • There are many different installers located in Massachusetts and the northeast states.  The design, installation, and interconnection of a generating facility can be complex, and it is advisable to consult a professional.
     
6. Does the Department regulate sellers of generating equipment or facility developers?
   • No, these industries are not subject to the Department’s authority.  If you have a dispute with a seller and wish to take formal action, you should contact the Attorney General’s Office or consider your other legal options.

1. If I am net metering, how will I be billed for electricity?
   • Customers who net meter are billed for their net consumption of electricity.  Depending on whether the customer used more electricity than was generated on site, or exported more to the electric grid, the customer will either owe the distribution company money or earn a monetary credit for the excess electricity that was generated and exported.  G.L. c. 164, § 139 .
   • Net Consumption = (total electricity consumed) - (total electricity generated).
     If net consumption is positive, the customer pays the electricity bill to the distribution company for the excess consumption. If net consumption is negative, the customer receives a monetary credit on their electricity bill and does not owe the distribution company for consumption during that billing period.

Example:  Imagine that you, a residential customer, install solar panels on the roof of your home.  Before daylight, your retail meter spins forward as you consume electricity from the electric distribution company to power appliances like a refrigerator or computer. During the day, the solar panels generate electricity.  If the solar panels provide more power than you use, your retail meter will spin in reverse while the excess electricity is sent to the electric grid.  At night, when the solar panels are not generating electricity, the retail meter will spin forward again as you consume electricity.  At the end of the billing period (approximately one month), you will pay for only your net consumption of electricity.

1. How can I apply my net metering credits to my bill?
   • Net metering credits can be used to offset the delivery and supply portions of your electric bill, as well as customer charges. Credits can be used to decrease your electricity bill to zero dollars and zero kilowatt-hour usage.  G.L. c. 164, §§ 138 , 139 .  220 C.M.R. § 18.04 .
     
2. What if I generate less electricity than I use?
   • You will receive a bill from the electric distribution company and will need to pay for the net electricity that you consumed. 220 C.M.R. § 18.03(4) .
3. What if my installation generates more electricity than I use?
   • The distribution company will calculate a credit for the excess electricity that you exported to the electric grid. The credit will appear on your bill and does not expire. 220 C.M.R. § 18.03(3) .
4. What is a Market Net Metering Credit?
   • On April 11, 2016, Governor Charlie Baker signed into law Chapter 75 of the Acts of 2016, An Act Relative to Solar Energy (“Solar Energy Act”).  Among other things, the Solar Energy Act required the Department to direct distribution companies to calculate Market Net Metering Credits after a specified time frame.  St. 2016, c. 75, § 4. The final net metering regulations, along with D.P.U. 16-64-C and 16-64-D. define and implement the Market Net Metering Credit for certain solar net metering facilities.  
     
     • Net metering credits generated by solar net metering facilities are calculated differently based on whether the facility generates net metering credits as calculated by distribution companies prior to implementation of the Solar Energy Act (“Old Regime”), or generates the Market Net Metering Credit (“New Regime”).
       
     • Market Net Metering Credits apply to Class I, II, and III solar net metering facilities and solar neighborhood net metering facilities, that are not cap exempt, that submit an ACA after September 26, 2016, or were first authorized to interconnect to the distribution system more than 25 years ago.  220 C.M.R. §§ 18.02, 18:04.  
       
     • The Market Net Metering Credit calculation is set forth in the final net metering regulations, 220 C.M.R. § 18:04 .
       
5. How can I determine if my solar net metering facility will generate credits resulting from net metering under the Old Regime or the New Regime?
   • Solar net metering facilities that are cap exempt generate credits calculated under the Old Regime. G.L. c. 164, §§ 138(i) ;  220 C.M.R. §§ 18:04(1), (5) .
     
   • Class I, II, and III solar net metering facilities or solar neighborhood net metering facilities, that are not cap exempt, will generate credits under the Old Regime, for 25 years from the date on which they were first authorized to interconnect to the distribution system, if all three of the following criteria are met: (1) submits an ACA before September 26, 2016; (2) receives notification from the Administrator that the ACA is complete; and (3) obtains a cap allocation by January 8, 2017.  D.P.U. 16-64-D at 12, 13 .
     
   • Class I, II, and III solar net metering facilities or solar neighborhood net metering facilities, that are not cap exempt, will receive Market Net Metering Credits if they submit an ACA after September 26, 2016, or submit an ACA before September 26, 2016, that is not complete, and/or does not receive a cap allocation by January 8, 2017.  220 C.M.R. §§ 18.02 and 18:04(3), (4), and (6) .
     
   • All Class I, II, and III solar net metering facilities and solar neighborhood net metering facilities will generate Market Net Metering Credits 25 years from the date on which they were first authorized to interconnect to the distribution system.  220 C.M.R. § 18:04 .
     
6. How can I determine the value of net metering credits for my excess electricity?
   • Net metering credits are calculated in a complex and detailed manner.

To help with your credit calculation, a mathematical formula is laid out in 220 C.M.R. 18.04. as well as in each distribution company’s net metering tariff.  The formula for the calculation of net metering credits is the same for all four electric distribution companies in Massachusetts.  Nonetheless, please note that the inputs for the formula include several variables that will vary between electric distribution companies and types of customers.

The formula includes several components, which may or may not be included in a net metering credit, based on the cap allocation application and receipt dates, type, and size (class) of the net metering facility producing the credits.

The below  table summarizes which rate components are included in credits resulting from net metering facilities of various types under both the Old and New regime.

Components for the Calculation of
Net Metering Credits

* Applies to Class III municipalities and other governmental entities under the Old Regime and all Class III net metering facilities under the New Regime.  

The following rates are never included in the calculation of net metering credits:  (1) fixed customer charges; (2) system benefit charges, including both the energy efficiency (also known as demand side management charges) and renewable energy charges; (3) demand charges (e.g.. $/kW or $/kVa charges) and (4) the Energy Efficiency Reconciliation Factor (“EERF”).  G.L. c. 164, § 138.

Once you know which rate components are included in net metering credits for excess generation produced by a net metering facility, you may consult your electric distribution company’s current schedule of rates.  Note that the relevant rate schedule will be determined by the Host Customer’s rate class (e.g., residential, commercial, etc.).  This will allow you to plug values into the credit formula and determine the value of a credit for each unit of excess electricity (in kilowatt hours) produced by your facility.  Be aware, however, that electric distribution companies’ rates change periodically.  For example, basic service rates for residential customers change every six months, based on the electric distribution company’s schedule for purchasing electricity supply in the marketplace.  Also, because each electric distribution company is purchasing electricity supply for its customers in a competitive marketplace, the basic service rate of one company will not necessarily be the same as the basic service rate of another company.  As a result, because basic service rates are a component of a net metering credit, the overall value of net metering credits can vary from one company to another.

1. What other costs are associated with net metering?
   • Net metering credit recipients will be responsible for paying fees to the System of Assurance to obtain a cap allocation and to the distribution company for interconnection.
     
   • Additionally, net metering credit recipients may have to pay a monthly minimum reliability contribution in the future.  The final net metering regulations describe the process through which distribution companies may submit proposals to the Department for a “monthly minimum reliability contribution to be included on electric bills for distribution utility accounts that receive Net Metering Credits.”  220 C.M.R. § 18:10.  The Solar Energy Act gives the Department the authority to consider proposals for a monthly minimum reliability contribution (“MMRC”).  G.L. c. 164, § 139(j).  St. 2016, c. 75, § 9.  More information can be found on the Department’s file room by entering 16-64.   
     
2. How long can an eligible facility generate net metering credits?
   • Under the current legislation and regulations. a facility can generate net metering credits indefinitely so long as the facility remains qualified as a net metering facility.
     
   • All Class I, II, and III Solar Net Metering Facilities and Solar Neighborhood Net Metering Facilities will generate Market Net Metering Credits at least 25 years from the date on which they were first authorized to interconnect to the distribution system.  220 C.M.R. § 18:04
     
3. What are the impacts of inclining block rates on net metering credit calculations?
   • Inclining block rates will result in slightly higher value net metering credits once a threshold for excess generation is met. For example, Unitil’s threshold is 600 kWh. Therefore, in Unitil’s service territory, the first 600 kWh of excess generation in a billing cycle will have a slightly lower monetary value than the additional kWh generated after the first 600 kWh.
     
4. How is my net metering class determined?
   • Your net metering class is determined by the type and capacity of the facility. 220 C.M.R. § 18.02 .

Size of Private Facility

Size of Public Facility

Class III Net Metering Facility

more than 1 MW but less than or equal to 2 MW

more than 1 MW but less than or equal to 10 MW

• • If your net metering facility contains existing and new generating equipment, the facility will be classified (i.e. Class I, II, or III) on the basis of the total generating capacity. D.P.U. 11‑11‑E  at 18.

1. Is there a difference between net metering and virtual net metering for the purpose of credit calculation?
   • Though some states differentiate between net metering (generation of electricity on the same site where it is consumed) versus virtual net metering (generation of electricity at another site than where the electricity is consumed), the Massachusetts net metering rules and regulations do not differentiate between net metering and virtual net metering. Therefore, for all purposes, including the credit calculation, there is no difference between net metering and virtual net metering.
     
2. What is the Net Metering Recovery Surcharge ("NMRS") ?
   • Net metering is an incentive for which all distribution company customers pay.  The NMRS is the mechanism to allocate the incentive costs to all customers in the distribution company’s service territory.
     
3. How can I track my net metering credits?
   • Net metering credits appear as a dollar amount on your electricity bill, and not as kilowatt-hours. These credits never expire and will rollover to subsequent billing periods.  These credits will continue to appear on your electricity bill until you use them.
     
4. How may I use my net metering credits?
   • First, a Host Customer can always use net metering credits to offset its bill from the electric distribution company.  Second, the Host Customer can allocate net metering credits to other accounts (even if they are not held by the Host Customer) as long as all of the accounts are:  (1) with the same electric distribution company; and (2) located within the same ISO-NE load zone  .  (Check with your electric distribution company for this information.)   Accordingly, a Host Customer may keep net metering credits, allocate net metering credits, or do some of each. 
   • A Host Customer decides how to apply the net metering credits to various accounts by completing and submitting a form called “Schedule Z” to its electric distribution company.  Schedule Z can be changed no more often than twice in one calendar year. Please check with your electric distribution company for more information about Schedule Z. G.L. c. 164, § 139(b)(1) .
     
5. Can I receive cash (also known as cash out) instead of net metering credits?
   • If a net metering facility has a capacity of  more than 1 MW (making it a Class III facility), the electric distribution company may decide to pay the Host Customer for the value of some or all of its net metering credits from excess generation, instead of applying the credits to its account(s).  Under G.L. c. 164, § 139(b)(1). this decision is left entirely up to the electric distribution company, but the electric distribution company must decide whether it will cash out and notify the Host Customer accordingly before the facility becomes operational.  220 C.M.R. § 18.05(4) .
     
6. Can I receive both net metering services and solar renewable energy certificates (“SRECs”) for the same solar project?
   • Net metering eligibility and SREC eligibility requirements are completely independent.  Please take note of the varying rules and criteria for each program.  For more information on the SREC program, please contact DOER .
     
7. How does compensation for excess generation differ between net metering facilities and QFs?
   • Please visit our Qualifying Facilities and On-Site Generating Facilities webpage for a comparison of the compensation for excess generation between net metering facilities and QFs.
     
8. If I have a facility that is net metering can that same facility also bid into ISO-NE’s forward capacity market (“FCM”)?
   • The distribution company has the right to bid the capacity of a Class II or Class III net metering facility into the FCM.  If the distribution company intends to exercise this right, the distribution company must notify the Host Customer within 30 days of the customer filing a Schedule Z.  
   • If the distribution company does not exercise this right, the Host Customer of a facility may bid the capacity of a net metering facility into the FCM.  Note that the Host Customer will have to work with the distribution company and ISO-NE in order to bid the capacity into the FCM.  For more information, please review Schedule Z and the net metering tariff.  For more information on participating in the FCM, please contact ISO-NE .
   • It is important to remember that penalties are possible for the Host Customer if the facility participates in the FCM but fails to deliver capacity when called upon.

1. What is the maximum capacity of a net metering facility?
   • A facility’s maximum capacity will depend upon whether it is a “public” or a “private” project.  If a net metering facility is designed for the private net metering cap, then the maximum capacity is 2 MW.  If a net metering facility is designed for the public net metering cap, then the maximum capacity is 10 MW.   A net metering facility designed for the public net metering cap may have multiple units, but the capacity of each unit cannot exceed 2 MW. G.L. c. 164, §§ 138 , 139(f) ; 11‑11‑C  at 15.
     
2. Is the net metering facility capacity calculated in alternating current (“AC”) or direct current (“DC”)?
   • The net metering facility capacity is calculated in AC. 220 C.M.R. 18.09(6).  
3. If a Host Customer allocates net metering credits to a public entity, is there any effect on the public entity’s 10 MW limit?
   • No, a public entity may receive an unlimited amount of net metering credits with no effect on its 10 MW limit.
   • The capacity of a net metering facility within the public cap only affects the Host Customer’s 10 MW limit.
4. What constitutes a net metering facility?
   • A “facility” is defined as the capacity located on a single parcel of land, at a single interconnection point, with a single meter.  D.P.U. 11‑11‑C  at 18‑23. 
     
5. What parcel boundaries does the Department recognize for the purposes of net metering?
   • In D.P.U. 11‑11–C  at 21­-22 . the Department recognized the validity of parcel boundaries established on or before January 1, 2010, which is the same date that DOER used for its solar carve out program.  Any customer who seeks to have newer parcel boundaries recognized for net metering must file a request with the Department.
6. May I build a net metering facility across two parcels of land?”
   •  A net metering facility is defined as “the energy generating equipment associated with a single parcel of land, interconnected with the distribution system at a single point, behind a single meter.”  D.P.U. 11 11 C   at 23.  Based on this definition, it is not permissible to construct more than one net metering facility on a single parcel of land, nor is it permissible to construct a single facility over two parcels of land without an exception from the Department.
7. Does merging two or more parcels of land into a single parcel require an exception for net metering purposes?
   • At the present time, merging two or more parcels of land does not require an exception from the Department.  If a land owner decides to legally merge one or more parcels, which must be reflected in documents filed with the relevant registry of deeds, then the Department would consider the land to be a single parcel for the purposes of net metering eligibility.  The owner of a net metering facility on merged parcels must ensure that the facility meets all other net metering eligibility standards.
     
8. Does subdividing a parcel into two or more parcels require an exception for net metering purposes?
   •  At the present time, any customer who seeks to establish a net metering facility on a parcel of land that was subdivided after January 1, 2010, must file a petition with the Department demonstrating that the subdivision was not for the purpose of creating multiple parcels specifically to support multiple net metering facilities (the “Subdivision Rule”) and receive Department approval.  D.P.U. 11-11-C at 22 .
   • For more information on how the Department has applied the Subdivision Rule see D.P.U. 14-93 and D.P.U. 15-132 . 
9. Are there any exceptions to the definition of “facility?”
   • Yes. In D.P.U. 11‑11‑E. the Department ruled that the distribution companies may grant exceptions to the definition of facility on the basis of optimal interconnection. The exceptions may include multiple interconnection points and multiple meters for a single facility.
   • Requests for exceptions to the single parcel rule must be addressed to the Department via a formal petition. For more information on submitting a petition to the Department, please see the questions in Section VII below.  D.P.U. 11‑11‑E .
     

• A “unit” is a component of a public net metering facility.  Units are defined differently, based on the type of technology used in the public net metering facility:
  • For public wind facilities, the number of turbine(s) will determine the number of units.
  • For public anaerobic digestion facilities, the number of engine(s) or turbine(s) will determine the number of units.
  • Public solar net metering facilities present a special case, and these facilities may self-designate their number of units, as long as there are at least as many inverters as the number of units. D.P.U. 11‑11‑C  at 15‑18. 
• The capacity of a single unit for a public net metering facility must be at least 60 kW and cannot exceed 2 MW.  Adding more meters or more interconnection points on a single parcel does not determine its units.  Subdividing one parcel into more parcels does not create units.  Having multiple owners or multiple recipients of net metering credits does not create units. 
  

• Which facilities belong in the public net metering cap?

• Pursuant to D.P.U. 11‑11‑D Appendix A  at 3, in order to be in the public cap, a facility must be a Class II or III
  1. that is owned or operated by a municipality or other governmental entity; or
  2. of which is the municipality or other governmental entity:
     1. is assigned 100 percent of the output,
     2. is the Host Customer, and
     3. if allocating net metering credits, allocates only to municipalities and other governmental entities.
• If a facility cannot fully meet the criteria outlined above, then the facility belongs in the private net metering cap. A facility cannot be in both caps at the same time
  

•  Who decides whether a net metering participant is a public entity?

•  Only the Department can classify participants as “municipalities” or “other governmental entities,” that is to say, as public entities.  There is no self-designation.  To receive this classification, a participant must file an application with the Department electronically.  A copy of the application and the instructions are located here:  Application for Municipality or Other Governmental Entity for Net Metering Pursuant to 220 C.M.R. § 18.00 et seq .

• There are three different situations where a public entity (either municipality or other governmental entity) would need to obtain a classification number:
  • A public entity that wants to start net metering.  A public entity will not be able to create an account at www.MassACA.org if it does not have a classification number (also called a public ID number) issued by the Massachusetts Department of Public Utilities; 
  • A public entity that is currently net metering; and
  • A public entity that is going to receive net metering credits from a separate public entity (through Schedule Z).

• What is a “neighborhood net metering facility?”

• A neighborhood net metering facility must: 
  • Only distribute net metering credits to customers that reside within the same neighborhood;
  • Distribute net metering credits to at least ten residential customers;
  • Not include the distribution charge in its net metering credits. 
• For more information about neighborhood net metering facilities, please refer to G.L. c. 164, § 138 , G.L. c. 164, § 140. and 220 C.M.R. § 18.02.

•  What is “community shared solar?”

• Community shared solar is a specific type of solar facility eligible for SRECs through DOER.  Net metering eligibility is not affected by a facility’s status as community shared solar.
• For more information about community shared solar, please visit DOER’s Community shared solar webpage or contact DOER directly.

1. If I want to petition the Department for an exception, what do I need to know?
   • If you are seeking a waiver from the Department’s rules, regulations, Orders, or other directives governing net metering services you must submit a petition to the Department.  There is a $100 filing fee to file a petition related to net metering with the Department.  801 C.M.R. § 4.02(9) .
   •  When drafting a petition, keep in mind that you must:   
     1. Follow the Department’s filing instructions ;
     2. Clearly identify the regulatory or decisional requirements for which an exception is sought. D.P.U. 15-124 at 2 ;
     3. Set forth the legal, business, commercial, economic, or other issues presented in connection with the requested exception. D.P.U. 15-124 at 2 ;  
     4. State the specific relief or remedy requested.  D.P.U. 15-124 at 2 ;
     5. Provide as much detail as possible in the petition and include any and all supporting materials with your filing. Be mindful to exclude confidential information that the Department does not need to review a petition (e.g. utility account number);
     6. Include an explanation of communication(s) with the Administrator of the System of Assurance and the affected electric distribution company concerning the issues underlying the petition in its petition. D.P.U. 15 124 at 8.  
     7. Include direct testimony or an affidavit from the petitioner or supporting witness(es).  D.P.U. 15-124 at 2, and 8, footnote 8, and D.P.U. 15-159 at 8, footnote 9. The Department provides sample affidavit language here .
     8. If petitioning under the good cause standard, explain how the request meets the good cause requirements for an exception. D.P.U. 15-124 at 2 ;
     9. If petitioning to have different boundaries recognized for the purposes of net metering or to build multiple net metering facilities on one parcel of land, provide a copy of the relevant filings with the Registry of Deeds.
     10. If petitioning to have net metering facilities on at least two parcels of land, provide a drawing showing the relationship of the proposed net metering facilities to the parcel boundaries as reflected in the relevant Registry of Deeds documents.
     11. If petitioning as an entity, such as a developer seeking to build more than one net metering facility on a single parcel, the entity must be represented by an attorney.
     12. Note that if petitioning as an individual, such as a homeowner seeking to build more than one facility on a single parcel, you may appear before the Department pro se, without legal representation.  
   • For guidance on how to draft your petition, please review a list of previous petitions, on the Open and Closed Net Metering Dockets webpage

1. How long will it take the Department to make a decision on a petition if I submit one?
   • The Department cannot provide a timeframe for a decision.  Each petition is unique.
   • All of the net metering petitions are listed on the Open and Closed Net Metering Dockets webpage, which may help provide a sense of timing.

1. What is the net metering “queue”?
2. What are the minimum requirements to submit an Application for a Cap Allocation (“ACA”) with the System of Assurance?
3. Does an Early ISA meet the executed ISA requirement for the System of Assurance?
4. When did the System of Assurance start accepting ACAs?
5. Must all facilities that want to net meter apply to the System of Assurance and reserve a cap allocation?
6. Why is the System of Assurance necessary?

1. What is the net metering “queue”?
   • The System of Assurance of Net Metering Eligibility, often referred to as the System of Assurance or the net metering “queue,” was created by the Massachusetts Department of Public Utilities:  (1) to track the aggregate capacity of all net metering facilities; and (2) to provide Host Customers and other stakeholders with an assurance, before beginning construction, that a facility will be eligible to receive net metering services once it is able to generate electricity.
2. What are the minimum requirements to submit an Application for a Cap Allocation (“ACA”) with the System of Assurance?
   • At a minimum, each of the following are required to submit an ACA: (1) an executed Interconnection Service Agreement (“ISA”) (i.e. signed by you and your utility); (2) site control; (3) all necessary governmental permits and approvals to construct the facility, with the exception of ministerial permits (i.e. building permit, etc.); and (4) an application fee of $100. D.P.U. 11‑11‑D Appendix A  at 3-4.
3. Does an Early ISA meet the executed ISA requirement for the System of Assurance?
   • In D.P.U. 11‑11‑F  at 16 . the Department directed the administrator of the System of Assurance to accept Early ISAs under the following conditions:
     • As of January 1, 2014, there will be no distinction between Early ISAs and the executed ISA requirement for the System of Assurance,
     • Prior to January 1, 2014, a customer may apply to the System of Assurance with an Early ISA as long as the customer submits an attestation that he/she received a written notice from the distribution company that their Detailed Study is complete.
4. When did the System of Assurance start accepting ACAs?
   • The System of Assurance started accepting ACAs on January 24, 2013.
5. Must all facilities that want to net meter apply to the System of Assurance and reserve a cap allocation?
   • No, pursuant to 220 C.M.R. § 18.07(5). a Class I net metering facility is exempt from applying to the System of Assurance if it can meet all of the following conditions:
     1. it is a renewable energy generating facility as defined by DOER (G.L. c. 25A, § 11F) ; and
     2.  its nameplate capacity is equal to or less than:
        1. 10 kW on a single-phase circuit; or
        2. 25 kW on a three-phase circuit
   • Note that these facilities are exempt from the net metering caps altogether and are called cap exempt facilities.  220 C.M.R. § 18.02 .
   • Furthermore, facilities that were net metering prior to January 24, 2013 (also known as grandfathered net metering facilities) do not need to apply for a cap allocation with the System of Assurance.
6. Why is the System of Assurance necessary?
   • The System of Assurance facilitates renewable energy development by reducing uncertainties about the availability of net metering services.  For more information about the System of Assurance or to review the aggregate capacity of net metering facilities in each utility company’s service territory, please visit:  www.MassACA.org .