SREC and MA Class I REC Reconciliation and True-up Guidelines

Overview

• The Solar Renewable Energy Certificates (SREC) and selected MA Class I Renewable Energy Certificates (MA Class I) Programs are  voluntary DOER incentive programs administered by MassCEC-PTS. Participation program compliance requires monthly production reporting to the Production Tracking System (PTS).
• Failure to report metered data during the reporting period may result in the forfeiture of SRECs and MA Class Is that would have otherwise been generated during the unreported period.
• Requests to reconcile production not reported to the PTS on time for the SREC and MA Class Is minting period are granted as an exception to reporting requirements at MassCEC’s determination within the following SREC and MA Class I Reconciliation Guidelines.
  
  

Identifying Reporting Issues

• GIS account holders are primarily responsible for monitoring production reporting, identifying reporting disruptions, and corresponding with MassCEC regarding issues with production reporting. GIS account holders must work with system owners, installers, and data acquisition service (DAS) providers to ensure compliance with reporting deadlines.
  • If production is not reported for a month, a GIS account holder should collaborate with the system owner, DAS provider, and installer, as applicable to address reporting issues.
  • GIS account holders should alert MassCEC PTS staff to communicate reporting issues and potential reporting delays if the problem cannot be in a timely manner to meet reporting deadlines.
• GIS account holders DAS providers can download the Missing Production Report to identify systems that are missing production for a given quarter.
  • As a courtesy, MassCEC emails this report to entities who are responsible for more than ten (10) systems that have missing production for the given month.
• System owners for systems 25 kW DC or less experiencing reporting issues with their auto-reporting through their DAS provider can manually report to maintain MA Class I and SREC compliance as problems are being resolved, or can permanently switch to manual reporting if they choose.

Submitting A Reconciliation Request Eligibility

Where eligible (as defined below), a GIS account holder may submit a reconciliation request. All requests must be submitted to MassCEC PTS staff for review via email at [e-mail]. The email must include the following information:

• PTS ID
• What is the issue?
• Has the issue been resolved?
• What month or period is being requested for a true-up?
• Please provide detailed information when describing the issue and what action was taken to fix the problem.
• Monthly production reporting must resume for a system to be SREC or MA Class I compliant before a true-up will be granted.
• Requests with generic explanations will be automatically denied. For example, a simple statement that “there was a communication issue” without additional detail would be denied
• The request should include what equipment was damaged, how it was impacted, when the matter began, and when was it or is it expected to be resolved. 

 In order to be eligible for MassCEC to perform a reconciliation of missing production data for a given system:

• The disruption to production reporting must be caused by: (i) an equipment hardware malfunction, such as a meter that has stopped recording production; or (ii) an Act of God (i.e., an accident or other natural event that could not have been prevented by reasonable foresight or care, such as a lightning strike). Human error is not considered an eligible basis.
• Every attempt must be made to address and correct the reporting issue prior to MassCEC’s quarterly SREC reporting deadline (see Submission Deadlines section below).
  • For example, if a system stops reporting in February, the matter should be addressed and resolved by the Q1 minting in July.
• Monthly production reporting must resume for a system to be MA Class I or SREC compliant and eligible for a reconciliation of missing production.
• If it is expected that the issue will not be resolved before the applicable minting period, MassCEC PTS staff must be notified of the situation, and a reconciliation request must be submitted by the Reconciliation Request Deadline (see below).
• If MassCEC PTS staff are notified of the delay in resolving the issue by the appropriate deadline and, after review, confirm the eligibility of the request, MassCEC PTS staff will perform a reconciliation of the production data once the matter has been resolved.
• In general, MassCEC will not perform reconciliation for production on more than a one-quarter delay. In the event of an extenuating circumstances that may result in more than a one-quarter delay, MassCEC PTS staff should be notified as soon as possible.

For example, based on the above, if a GIS account holder notifies MassCEC PTS staff of a delay in resolving reporting issues for Q1 (Jan-Mar) and submits a reconciliation request by July 1^st, and the system fixes the reporting problem and resumes reporting in August, then the system will receive a Q1 reconciliation during the Q2, October minting period.

Submission Deadlines

Reconciliation requests must be submitted to PTS by the following deadlines to ensure timely review, approval, and processing within the approved quarter:

SREC/MA Class I Minting Quarter	Reconciliation Request Deadline
Q1 (Jan-Mar)	July 1st
Q2 (Apr-Jun)	October 1st
Q3 (Jul-Sep)	January 1st
Q4 (Oct-Dec)	April 1st

Non-Eligibility

Reconciliation requests will be denied if any of the following are the basis for production issues: 

• Internet or cell service connection issues not due to a meter malfunction (including the 3G shutdown - please see the 3G Shutdown section below for more information);
• Login issues where the account holder does not request assistance from MassCEC PTS staff within the required monthly reporting period (so as to not affect the quarterly NEPOOL reporting) that provides MassCEC a commercially reasonable opportunity to assist;
• DAS provider subscription lapses;
• Software configuration issues;
• Untimely notifications to MassCEC PTS staff and DOER of ownership transfers, meter swaps, and other user errors (see here for guidance re: ownership transfers - https://masscec-pts.zendesk.com/hc/en-us/articles/13495785660187-Change-Request-System-Owner); and
• Disruptions with indeterminate causes.

Reconciliation requests that do not comply with the Submission Deadlines outlined above absent extenuating circumstances that justify the request will be denied. For example, requests due to the failure of a system aggregator, as GIS account holder, to notify a system owner of production reporting disruptions in a timely fashion that result in missing a Submission Deadline will not be eligible for reconciliation. In such instances, MassCEC encourages system owners to engage their aggregators to address any consequences associated with missing and/or forfeiting production.  

Additionally, to the extent MassCEC PTS staff determine that granting a reconciliation request would have a materially detrimental effect on DOER’s Renewable Energy Portfolio Standards for a given compliance year (see 225 CMR 14.00), MassCEC reserves the right to reject the reconciliation request even if the request would otherwise be a eligible pursuant to these guidelines.

3G Shutdown

Systems 25 kW or under

• If experiencing reporting issues due to the shutdown of 3G wireless networks that took place in 2022, the GIS account holder (or System Owner, if different) may request the system reporting be switched to manual reporting until the auto-reporting matter is resolved.
  • If switched to manual reporting temporarily, MassCEC PTS staff must be notified when the auto-reporting issue is resolved and request the reporter be updated to return to the DAS reporter for auto reporting to resume. Additionally, MassCEC PTS Staff must be provided with the correct meter swap information to complete this update.
• MassCEC PTS staff will not grant reconciliation requests for systems experiencing reporting disruptions in instances where GIS account holders choose not to manually report or do not provide notification of meter swaps/reporters updates in a timely manner. See Eligibility section above.

Systems Over 25 KW

• During 2022, MassCEC PTS staff offered the opportunity for systems to provide one manual production data reading from the reporting window for either Q2 or Q3 minting periods as a courtesy to assist with maintaining the system’s SREC or MA Class I compliance requirement. At this point in time, MassCEC is not accepting further manual production readings for systems of this size.
• As outlined in the Eligibility criteria, MassCEC PTS staff must be notified of all meter swaps promptly.
• MassCEC PTS staff must be notified of any ongoing issues, such as a backlogged meter order, which will continue impacting systems.

SREC/ MA Class I Compliance Year

• In general, reconciliation will not be granted for a system’s production generated in a prior SREC/MA Class I compliance year. The main exception to this is for a reconciliation request for Q4, which must be submitted for review and approval prior to the Submission Deadline for Q1 of the following SREC/MA Class I compliance year. Every effort must be made to resolve production reporting issues by the Q4 SREC minting in April, which is the last opportunity to generate SRECs/MA Class I RECs for that compliance year.
• If a system is missing Q4 production and cannot resolve to report by NEPOOL’s April minting deadline, MassCEC PTS must be notified of the issue by April 1st. If MassCEC PTS staff are not notified by this deadline, the production will be subject to forfeit.

Extenuating Circumstances

• Significant reconciliations (>100 MW) in a single quarter are reviewed by the Program Manager/Director.
• Reconciliation requests that based on unique, extenuating circumstances will be reviewed by the Program Manager/Director and approved or denied on a case-by-case bases. Cases in dispute with the Program Manager/Director’s decisions will be reviewed by DOER to assist with all dispute resolutions.

Updated: April 2024