Massachusetts energy storage, net metering, and capacity market inquiry

Massachusetts utility regulators have opened an inquiry to investigate the eligibility of energy storage systems paired with net metering facilities to net meter and the qualification and bidding of certain net metering facilities in the Forward Capacity Market administered by ISO New England Inc.

The existing Massachusetts statutes and regulations allow customers to "net meter," or to generate credits for excess electricity generated by an eligible net metering facility.  Massachusetts allows a customer may install any type of generating facility, regardless of fuel source, as long as the facility is 60 kilowatts or less; if they generate electricity with renewable fuels (i.e., wind, solar photovoltaics, and anaerobic digestion), facilities can be up to two megawatts, or ten megawatts in the case of certain public facilities.

But the Massachusetts net metering statutes and regulations do not explicitly address how energy storage resources fit into the net metering program.  Several recent cases before the Department of Public Utilities have raised questions about the intersection of energy storage and net metering, as well as about what utilities should do to obtain payments for capacity products associated with solar net metering facilities.

On October 3, 2017, the Massachusetts Department of Public Utilities issued an Order Opening Inquiry into these issues.  Regarding the eligibility of energy storage systems to net meter, the Department posed a series of questions on which it requested initial written comments no later than 5:00 p.m. on November 17, 2017, with written reply comments not later than 5:00 p.m. on December 8, 2017. Questions include whether net metering facilities paired with energy storage systems be eligible to net meter.  The order expresses concerns about avoiding "gaming and manipulation of the net metering rules and regulations," and the Department's expectation that a net metering facility paired with an energy storage system would need to be configured such that the energy torage system is charged only from the net metering facility and cannot export power to the electric grid.

The Department also requested comment by February 1, 2018, on questions relating to the participation of net metering systems in the ISO-NE Forward Capacity Market or FCM.