The Honorable Jeffrey N. Roy, House Chair
The Honorable Michael J. Barrett, Senate Chair
Joint Committee on Telecommunications, Utilities and Energy
State House, Boston

Delivered electronically

Dear Chair Roy, Chair Barrett, and Distinguished Members of the Committee,

On behalf of the cities and towns of the Commonwealth, the Massachusetts Municipal Association is pleased to submit comments in support of H. 3135 and S. 2130, An Act relative to monthly minimum reliability contributions. This legislation would exempt municipal ratepayers, low-income, community solar, and small-scale ratepayers from paying a monthly minimum reliability contribution (MMRC).

As currently written, the state’s net metering law allows utility companies to submit proposals to the Department of Public Utilities for a monthly minimum reliability contribution payment to be included on electric bills for customers who receive net metering credits. These proposals are subject to the review and approval of the DPU.

These charges are assessed to distribute the “fixed costs of ensuring the reliability, proper maintenance, and safety of the electric distribution system” on net-metered solar customers. Low-income ratepayers can be exempted from MMRC charges through existing law, but municipalities that have pursued, purchased and installed solar as part of their municipal energy systems could be subject to these additional charges without the protection provided by H. 3135 and S. 2130.

In addition to municipal ratepayers, community solar ratepayers and owners of small-scale solar projects of 25 kilowatts or less could be found responsible for paying these monthly charges, should a utility company pursue an MMRC through the established process. The expansion of the existing MMRC exemption to include municipal, community solar, and small-scale solar ratepayers would further incentivize solar development, which will be essential in meeting the Commonwealth’s goals for renewable energy.

Additionally, potential MMRCs could have a negative financial impact on both new and existing municipal solar projects. Such an unexpected fee can shift the delicate financial calculus that municipalities and others employ to determine the feasibility of solar projects. The MMA and its members oppose any MMRC charges on municipal solar customers, and strongly support the permanent exemption proposed in H. 3135 and S. 2130.

Local leaders are constantly searching for opportunities to strengthen and build opportunities for renewable energy, and an unanticipated charge could disincentivize municipalities and other partners from pursuing net metering and solar energy in the Commonwealth. Therefore, we respectfully ask the Committee to favorably report out H. 3135 and S. 2130.

We appreciate your consideration of this important issue. If you have any questions, please do not hesitate to have your office contact me or MMA Legislative Analyst Josie Ahlberg at jahlberg@mma.org at any time.

Thank you very much for your ongoing support of cities and towns.

Sincerely,

Geoffrey C. Beckwith
MMA Executive Director & CEO

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