SMART Program Requests for Extensions and Exceptions

See below for information on how to submit a request for an exception or an extension.

The Department is now processing SMART Good Cause Extension Requests submitted through 4-11-2024.

Please note: This webpage is for informational purposes only. Stakeholders should always reference 225 CMR 20.00 and DOER's official SMART Program Guidelines to determine eligibility criteria for potential extensions or exceptions for a Solar Tariff Generation Unit (STGU) participating in the SMART Program.

Requests for an Extended Reservation Period

The Department may grant extensions to a STGU's initial Reservation Period under the following circumstances:

  1. Extension for a Fee (both for the STGU and/or a co-located Energy Storage System)
  2. Extension for a Legal Challenge
  3. Extension Pending Authorization to Interconnect (ATI)
  4. Extension Pending Affected System Operator (ASO) Study
  5. Extension for COVID-19
  6. Extension for Good Cause

The eligibility criteria for possible extensions in the SMART Program can be found in Section 6 of the Statement of Qualification Reservation Period Guideline.

To request a good cause extension, applicants must submit this online Good Cause Extension Request FormPlease note that an extension request will also need to be filed via the Extension Request Form in the SMART portal for the Solar Tariff Generation Unit (STGU) in question. Filing the relevant extension request in the SMART portal will place the STGU back in Extension Review status while the extension request is pending with the Department. For any questions as to relevant extensions, please email the SMART inbox at For any issues with the SMART portal, please email the Solar Program Administrator, CLEAResult, at

Applicants seeking to submit a legal challenge extension or additional time under the ASO Study extension due to further study should continue to submit their request via email to and include the information listed below.

  • Applicant's contact information and affiliation to the STGU (e.g. Applicant, STGU Owner, legal counsel, etc.).
  • SMART Application ID Number (i.e. the ID beginning with SMAES_,SMANG_, or SMAUN_).
  • Confirmation as to whether the STGU has already received the fee-based extension under Section 6(a) of the Statement of Qualification Reservation Period Guideline. (Note: this is only required for good cause extension submittals.)
  • Confirmation of additional extensions the STGU has received under Section 6 of the Statement of Qualification Reservation Period Guideline and when the STGU received any the extension(s), if applicable.
  • The current expiration date of the STGU's preliminary Statement of Qualification.
  • A letter with a complete narrative as to why you are seeking an extension. The letter may be addressed to Samantha Meserve, Director of the Renewable and Alternative Energy Division at DOER.
  • Any additional supporting documentation, as necessary (e.g. timeline of events causing the delay, relevant legal documents, third party communications, construction schedules, etc.).

Requests for a fee-based extension, initial ASO Study extension, or an indefinite extension pending ATI may be submitted through the SMART application portal.

Questions about eligibility criteria for extensions should be directed to Questions related to the application portal should be directed to the Solar Program Administrator at

DOER strongly encourages Applicants to submit an extension request well in advance of the STGU's Reservation Period deadline to allow for proper review time by DOER staff members. If a STGU's expiration date is approaching while an extension request is pending before the Department, applicants should also submit the extension request in the SMART application portal to place a hold on the Reservation Period deadline until a determination letter is issued.

In instances where DOER denies an Applicant's extension request for a project that has passed its Preliminary Statement of Qualification deadline date, the Applicant may submit a Request for Reconsideration. The Request must be submitted to DOER within 30 days of the denial letter's issuance and should provide new information for DOER to evaluate. If no Request for Reconsideration is submitted, the STGU will remain in a Denied status and the capacity will be reallocated to the current Capacity Block.

Requests for Exceptions

Under certain limited circumstances and as allowed by regulations, DOER may permit an exception to specific program rules for good cause. In the exception request, the applicant must identify the applicable exception under 225 CMR 20.00 and demonstrate to the Department’s satisfaction that good cause warrants an exception. All good cause exception requests are reviewed by DOER on a case by case basis and should be directed to

Potential good cause exceptions may include:

  1. Good Cause Exception to the Project Segmentation rules under 225 CMR 20.05(5)(g)8.
  2. Good Cause Exception to Greenfield Subtractor under 225 CMR 20.07(4)(g)5.b.
  3. Good Cause Exception to the Energy Storage Requirement under 225 CMR 20.05(5)(k)1.b.

Additional guidance on possible exceptions to Project Segmentation rules can be found in Section 6 of the Land Use, Siting, and Project Segmentation Guideline. Additional guidance on possible exceptions to the Energy Storage Requirement may be found in Section 4 of the Energy Storage Guideline.

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