Dear Massachusetts APS Stakeholders,   

The Department of Energy Resources (DOER) provides notice to stakeholders that on October 13, 2017, DOER filed an amended draft regulation with Joint Committee on Telecommunications, Utilities and Energy to include renewable thermal, fuel cells, and waste-to-energy thermal technologies in the Alternative Energy Portfolio Standard (APS). The draft regulation and accompanying guidelines have been posted to DOER’s website for stakeholder review.

Since the close of the written comment period on August 7, 2017, DOER has made revisions in response to stakeholder input. These include, but are not necessarily limited to the following:  

Woody Biomas

• Revised the definition of Eligible Biomass Woody Fuel and Sustainable Forestry Management;
• Clarified requirements for Biomass Sustainability;
• Added a provision that sets a minimum percentage of feedstock used in the creation of Eligible Biomass Woody Fuel that must come from various forest derived sources;
• Added a requirement for DOER to complete a 2018 baseline review of the impacts on Massachusetts forests;
• Added auditing requirements for Eligible Biomass Woody Fuel suppliers; and
• Revised various fuel specification and performance requirements.

These revisions can be found in 225 CMR 16.02, 225 CMR 16.05(4), 225 CMR 16.11, DOER’s Guideline on Biomass, Biogas, and Biofuels for Eligible Renewable Thermal Generation Units and Guideline on Reduction of Greenhouse Gases for Eligible Renewable Thermal Generation Units Using Eligible Woody Biomass. 

DOER reorganized the quarterly caps on the available number of attributes for Generation Units using Eligible Liquid Biofuels. The 20% cap has been retained and is split two periods, with equal to or less than 10% of attributes eligible to be minted from January 1st – June 30th and the remainder available from July 1st – December 31st.

DOER also aligned the APS requirements for Eligible Liquid Biofuels with the Environmental Protection Agency’s Renewable Fuel Standard, including removing the requirement for a Quality Assurance Plan.

These revisions can be found in 225 CMR 16.05(4).

Compost Heat Exchange Systems

DOER has added compost heat exchange systems as an eligible Renewable Thermal Generation Unit. 

The definition of compost heat exchange systems can be found in 225 CMR 16.05(1)(a)(6)(viii).

Fuel Cells

DOER has revised the 60% efficiency threshold and modified eligibility for behind-the-meter, electric only, fuel cells to those interconnected to the Massachusetts electric grid. 

These revisions can be found in 225 CMR 16.05(1)(a)7 and 225 CMR 16.05(1)(d)2.

DOER has added a multiplier for compost heat recovery systems and revised the multipliers for intermediate and large, partial air source heat pump systems.

These revisions can be found in DOER’s Guideline on Metering and Calculating the Useful Thermal Output of Eligible Renewable Thermal Generation Units.

Combination of Funding Provision

DOER has removed the combination of funding provisions for Generation Units which received funding from the Massachusetts Clean Energy Center, and increased the maximum combination of funding percentage from DOER or any other state agency to 80%.

These revisions can be found in 225 CMR 16.05(1)(a)(6)(d).

DOER made several changes to revise technical details and language inconsistencies in the regulation and Guidelines.

If you have questions on the documents that have been posted or the rulemaking process, DOER asks that you please direct them to thermal.doer@state.ma.us.

Regards,

Michael Judge

Director, Renewable and Alternative Energy