Oct 28, 2025
Smart 3.0 Is Here
SMART 3.0 is here and here’s what you need to know.
225 CMR 28.00 is the official DOER regulation (effective September 2025) that defines the technical and commercial rules for solar and storage participation under the SMART 3.0 incentive program, with the core goals of reducing greenhouse gas emissions, improving grid reliability, peak shaving, protecting land-use, and alignment with the MA 2050 decarbonization plan. The rules apply to distribution companies, and all owners, authorized agents and primary installers of Solar Tariff Generation Units (STGUs)
It is important to note that participation is voluntary but binding – each participant must comply with all 28.00 requirements, or as amended by the DOER. The second enrollment period starts on January 2, 2026.
The DOER assigns capacity annually by utility load share:
10% for systems 25-500 kW
10% for low-income property
And 15% for community shared solar
It is important to note that unused capacity does not roll over
Program year 2026 will have 450 MW of available capacity for STGUs subject to the capacity cap
Base compensation rates and adders will be baselined annually – it is expected to change by ~$0.01 per kWh.
Fundamental calculation remains the same:
Base compensation rate for program year 2025 for projects > 1 MW is $0.1729 per kWh
The base compensation rate proposed for program year 2026 for projects > 1 MW is $0.1556 per kWh
Adder rates are as follows:
Energy Storage Adder:
AC-coupled: The SMART 3.0 calculator will be made available on the mass.gov webpage. It is free to download and easy to use to determine the appropriate storage adder applicable for the project.
An applicant will reserve an adder multiplier rate upon the initial application for the Energy Storage Adder. However, changes to as-built solar photovoltaic (PV) capacity or the Energy Storage System relative to the information contained in the initial application may result in an increase or decrease to the size of the Energy Storage Adder. Additional information on applying for the Energy Storage Adder is provided in the Statement of Qualification Reservation Period Guideline
DC-coupled true-up:
For DC-coupled STGUs with Energy Storage Systems, there are round-trip efficiency losses resulting in lower generation at the production meter. To compensate STGU owners for the AC equivalent of the renewable energy production of the STGU and to calculate the annual true-up payment of the round-trip efficiency losses, an applicant shall use the following formula:
i = the number of intervals in a calendar year
Ei = 15-minute interval ESS DC net metered energy output
ηT = fixed transformer efficiency factor
ηINV = fixed inverter efficiency factor
RP = SMART incentive rate for the STGU
The Department shall establish a transformer efficiency factor that shall be fixed for all STGUs and an inverter efficiency factor that will be fixed for the specific inverter utilized by the STGU. The current established transformer efficiency factor is 2. To receive the annual true up payment, the Energy Storage System’s performance data and inverter efficiency factor must be reported to the Department. On an annual basis, the Department will calculate the annual true up payment. Once calculated, the Solar Program Administrator will provide the data to the Department for verification prior to submittal to the appropriate Electric Distribution Company for payment to the STGU Owner.
Administrative process flow:
Projects ≥ 1 MW must attest to or file FERC QF status under PURPA
Submit a Statement of Qualification (SOQ)
DOER issues preliminary SOQ – 24-month reservation period
Upon interconnection authorization, apply for final SOQ with financial proofs and BESS compliance
Ground-mount projects must also secure all non-ministerial permits, such as planning board and conversation commission approvals
Capacity is allocated on a first-come basis (generally, first 10 business days sequenced by ISA application date
Waitlist mechanism defined with 10-day response window
General requirements:
PV must be ≤ 5 MW AC: 10 MW AC for brownfield or landfills
Delivery point must be physically in MA
No active SMART 2.0 SOQ
All STGUs > 1 MW AC that do not qualify for a locational adder (e.g., brownfield, landfill, dual-use, floating, etc.) must be co-located with an ESS that meet 225 CMR 28.07 (5) (e) 1
Brownfield: up to 10 MW, ISA exceptions are allowed with pre-determination from the MassDEP
Canopy: must be raised so that at least 75% of area underneath be usable
Dual-use Ag: trackers must be at least 8-ft for fixed tilt or 10-ft tracking; ≤2:1 DC:AC ratio (≤ 7.5 MW DC); and agricultural plan is required
Floating: PFAS-free material; ≤ 50% surface coverage; ≤ 40 MW statewide cap
Public entity/low-income/community shared solar: ≥ 40% allocation and ≥ 20-40% bill credit discount
DOER can grant exceptions on a case-by-case basis for good cause, like transmission constraints or non-viable interconnection
ESS must be at least 2 hours in discharge duration, at least 65% RTE at the POI, and must demonstrate > 52 cycles per year with proper metering (15-minute intervals) and reporting (1Y historian)
The ESS must also be at least 25% capacity of the PV plant
Land-use controls and mitigation fee (§ 28.08-28.09)
Replaces “greenfield subtractor” with a project-specific Mitigation Fee for ground-mount > 250 kW on undeveloped land.
Fee calculated per acre based on habitat, prime farmland, and carbon-risk layers (Bio Map, MassGIS datasets).
25% is due at the time of SOQ application, balance at Final SOQ; refundable if project is canceled or site reclaimed.
SMART 3.0 represents a significant evolution in Massachusetts’ approach to distributed solar and storage, bringing clearer requirements, stronger land-use protections, and incentive structures aligned with long-term decarbonization goals. As developers, owners, and installers prepare for the 2026 program year, understanding the regulatory updates and technical obligations will be critical to securing capacity and maximizing project value. With careful planning and proactive compliance, participants can successfully navigate SMART 3.0 and contribute to a more resilient, clean, and reliable energy future for the Commonwealth.