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Distributed Generation Amendment Act of 2011 Implemented

Tuesday, September 27th, 2011

The Council of the District of Columbia and the city’s Mayor signed into law the Distributed Generation Amendment Act of 2011. SRECTrade closely watched this legislation as it evolved over the last 7 months. Our most recent blog on the subject is here. The Act ultimately focuses on providing a sustainable SREC market for the residents of Washington DC while containing the potential cost to ratepayers. The amendment increases the RPS solar requirements and closes the District’s boarders from out-of-district sited systems. The affect on the market is demonstrated in our Capacity Update of systems eligible to create DC SRECs moving forward.

This week, the PJM tracking registry (PJM GATS) is undergoing the process of de-certifying systems that were once eligible under the previous Washington DC RPS law. As per the new legislation, all non-Washington DC sited systems that were approved after January 31, 2011 by the DC Public Service Commission are no longer eligible to sell SRECs in the DC market. This cutoff date is clearly displayed by a customer’s DC State Certification Number; any certification number beginning “DC-10…-SUN-I” was certified before January 31, 2011, while any certification number beginning “DC-11….-SUN-I” was certified after that date.

What does this mean for the market?

While this law is not likely to cause DC SREC prices to rebound immediately to the level that was seen in 2010 (due to the fact that buyers have likely accumulated extra SRECs throughout the early part of this year, along with any forward contracts that were in place before the law was implemented), this law is an important step to alleviating the oversupply that has depressed DC SREC prices.

What does this mean for facilities certified after January 31, 2011?

Any facility not located within Washington DC with the state certification number beginning “DC-11…” has had their certification number de-activated. The facility is no longer eligible to generate future SRECs in the DC market, and any SRECs they have already created have lost their eligibility for the DC SREC market.

- If your facility falls under this category, and is already eligible to sell SRECs in another state, you will not see any disruption in your account except that you are no longer eligible for the DC market.

- If your facility is eligible to be certified for another SREC market, but you were only certified in DC, you can apply for certification in another state market. Please see this chart for more information on your eligibility.

- If your facility was originally only eligible for DC (i.e. your system is located in WI, NY, NC(non-Dominion Power territory) or you had a Solar Thermal system not located within Washington DC), PJM GATS will be listing your facility as “inactive”. Any SRECs you have created will not be eligible for sale, and you will not create future SRECs unless another market opens that allows your facility to be certified. Currently, solar facilities in this scenario are only eligible in the NC SREC market – but due to extremely low pricing in the oversaturated NC market, this option is not very viable for solar owners.

SRECTrade will continue to post opportunities for cross-listing SRECs in other state markets.

Distributed Generation Amendment Act of 2011 Implemented

DC Closes Borders to Out-of-State Solar Systems

Tuesday, July 12th, 2011

The Council of the District of Columbia unanimously voted, today July 12th, to close the DC SREC market to out-of-state systems. The Distributed Generation Amendment Act of 2011 (Bill 19-10) increases the SREC requirement in 2011 as well as establishes an SACP schedule through 2023.  Once in effect, the bill will allow out-of-state systems registered prior to 1/31/2011 to continue to sell SRECs in the DC market. The DC Public Services Commission has not provided clarification on how the bill will affect out of state systems that have already granted DC registrations after the January 31st 2011 grandfather date. For more information on the bill please refer to our previous blog postings here and here.

The bill is not yet law. It first must go through a 30-day Congressional Review process before it can go in to effect. Given these mechanistic delays we don’t expect the bill to go in to effect for at least another month.

The following chart illustrates which out-of-state systems will be effected by the legislation.


State Eligible Markets (after B19-10 is effective)
DE DE, PA
IN OH; PA (if in American Electric Power territory)
IL PA (if in Com Ed territory)
KY OH; PA (if in American Electric Power territory)
MD MD; PA
MI OH; PA (if in American Electric Power territory)
NC NC; PA (if in Dominion Electric Territory)
NJ NJ, PA
NY -
OH OH; PA
PA PA; OH
TN PA (if in American Electric Power territory)
VA PA
WV OH; PA
WI -

DC Closes Borders to Out-of-State Solar Systems

DC SREC Market Amendment – Update

Wednesday, June 15th, 2011

On June 7, 2011, the Council of the District of Columbia read and reviewed the latest draft of Bill 19-10, also known as the Distributed Generation Amendment Act of 2011.  For the details of the pending amendment please click here. The amendment received a substantial support from the local legislators as well as the DC solar community. The final vote after the first reading was 14-0, unanimously in favor of putting the amendment into effect.

As it currently stands, below are the key points of the amendment under consideration:

- Solar thermal system eligibility to participate in the SREC market. For more info see this post.

- Implementation of new solar capacity requirements and a new solar alternative compliance payment (SACP) schedule:


Year Current RPS Solar Requirement Proposed RPS Solar Requirement Jan-11 Proposed RPS Solar Requirement June-11 Current SACP Proposed SACP June-11
2011 0.04% 0.25% 0.40% $500 $500
2012 0.07% 0.50% 0.50% $500 $500
2013 0.10% 0.75% 0.50% $500 $500
2014 0.13% 1.00% 0.60% $500 $500
2015 0.17% 1.25% 0.70% $500 $500
2016 0.21% 1.50% 0.825% $500 $500
2017 0.25% 1.75% 0.98% $500 $350
2018 0.30% 2.00% 1.15% $500 $300
2019 0.35% 2.25% 1.35% $500 $200
2020 0.40% 2.50% 1.58% $500 $200
2021 1.85% $150
2022 2.175% $150
2023 2.50% $50

The amendment puts it place a system size cap, stating that all solar requirements be met by acquiring SRECs from systems no larger than 5 MW. Additionally, the amendment requires systems to be sited within the District. For systems located outside of the District, the amendment plans to grandfather systems smaller than 5 MW in capacity that were registered as a renewable resource with the District prior to January 31, 2011.

As mentioned in our previous blog post on this potential change to the District’s existing RPS law, this bill will take very important, concrete steps to addressing the current oversupply in the DC market.

It is still unclear how the grandfather date of 1/31/2011 will affect facilities outside the district that have been registered by the DC Public Services Commission and issued SRECs since then.

As the District is still operating under the current RPS law, out-of-state systems are still eligible to be certified for SREC generation, but it is unknown if the registration will hold value considering the implications of the amendment. The DC Council website does not currently indicate the next date for further consideration, but SRECTrade will continue to provide additional information as it becomes available.

DC SREC Market Amendment – Update

Solar Thermal SRECs in DC – Update

Tuesday, April 12th, 2011

Recent legislation passed by the council of the District of Columbia now allows non-residential solar thermal systems to be registered to produce DC SRECs. Under the new legislation non-residential systems must be SRCC OG-100 certified. The legislation went into effect on March 12, 2011 and will expire on October 23, 2011. Previously the District only accepted SRECs from residential SRCC OG-300 certified solar thermal systems.

The new legislation has the following requirements for solar thermal systems:

Solar thermal non-residential systems producing or displacing more than 10,000 kW-hrs per year must be SRCC OG-100 certified and the annual energy output must be determined by an onsite OIML compliant meter.

Solar thermal non-residential systems producing or displacing 10,000 kW-hrs or less per year must be SRCC OG-100 certified and their annual energy output can be determined by the SRCC OG-300 performance rating protocol OR by an onsite OIML compliant meter.

Residential SRCC OG-300 certified solar thermal systems are not affected by this legislation and can continue to be registered in DC.

Given the current supply dynamics of the DC SREC market, this legislation will continue to provide more supply to the oversubscribed program. While SREC prices could continue to decline in the near term, it may be beneficial for solar thermal system owners, previously not eligible for the DC market, to register and receive certification as an option for potential SREC liquidity.

For an update on the current capacity certified to produce DC SRECs see the SRECTrade SREC Markets Report: March 2011.

Additionally, the Distributed Generation Amendment Act of 2011, could have a positive impact on the oversupplied DC SREC market. The legislation is still pending and details associated with the cut off date for grandfathering in out of state DC registered systems are still unknown. SRECTrade will continue to monitor this piece of legislation and provide additional information as it becomes available. For more background on the proposed amendment see these blog posts:

Could Change Be Coming to Washington DC’s SREC Market?

DC Bill Introduced to Limit Out-of-State Facilities

For information on registering a solar thermal system directly with DC Public Services Commission see this page, or consider registering through SRECTrade’s EasyREC service.

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Solar Thermal SRECs in DC – Update

Could change be coming to Washington DC’s SREC market?

Wednesday, February 9th, 2011

As you can see from our monthly update on the capacity registered in the SREC states, the DC market has requirements of no more than 8 MW of installations over the next two years. Today, there are over 27 MW currently generating SRECs that are eligible for the DC SREC market. Only 1.1 MW of the 27 MW are actually located within the District. This oversupply and weight towards foreign facilities is likely what prompted the potential legislative changes to the DC SREC market that we highlighted earlier.

This Bill is still in the early stages of the legislative process and it is unknown how long it would be before it is passed. However, it will take several months, at a minimum, before it would go into effect. At this point, it has been referred to the Committee on Public Services and Consumer Affairs, chaired by Councilmember Yvette Alexander who will establish the timing of hearings and markups of legislation.

After the hearing, it will likely go through an iterative process that will take several weeks before it is ready for a vote and another 2-4 weeks before a 2nd and final vote to enact the Bill before it is sent to the Mayor to sign. Once signed by the Mayor, the District must then send it to Congress for a lengthy review period.

The Bill seems to have enough support within the Council to have a good chance of being passed. Which then begs the question, how will they approach the grandfathering of out-of-state facilities that are already registered in DC. There are two important details here. First is the cutoff date. The initial date listed on the proposed Bill was January 31, 2011, however it is likely that if it takes several months to a year to enact the law, the actual cutoff date will be adjusted accordingly. The second detail is what defines “registered”. Would it mean any facility that was built prior to the cutoff date? Or is it any facility that has submitted an application to DC prior to the cutoff date? Or is it any facility that is approved prior to the cutoff date? The problem with the third approach is that the date an application is submitted is within the control of the solar owner, but the date that it is actually certified is not. We think it would be consistent with existing policies that DC would interpret “registered” as the date by which an application is submitted to DC.

SRECTrade will continue to follow the progress of this legislation. Any stakeholders interested in submitting testimony can do so by contacting the office of Councilmember Alexander.

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Could change be coming to Washington DC’s SREC market?

DC Bill introduced to limit out-of-state facilities

Friday, January 14th, 2011

Washington, DC Councilmember Mary M. Cheh has introduced a Bill to amend the solar carve-out in the District. It is called the Distributed Generation Amendment Act of 2011. The announcement can be found here. Among the changes, the most notable will restrict the DC SREC market to facilities located in the District, starting in 2012. The Bill will grandfather any facilities registered in DC prior to January 31, 2011. In addition to this notable change, the requirements in each year will increase significantly through 2020 and the SACP will be extended until 2020. Here are the key details:

1. Facilities sited outside D.C. will remain eligible as long as they were registered with the D.C. Public Service Commission prior to January 31, 2011.

2. Starting in 2011, solar requirements will increase as follows:

Year Old RPS Solar Requirement New RPS Solar Requirement SACP
2011 0.04% 0.25% $500
2012 0.07% 0.50% $500
2013 0.10% 0.75% $500
2014 0.13% 1.00% $500
2015 0.17% 1.25% $500
2016 0.21% 1.50% $500
2017 0.25% 1.75% $500
2018 0.30% 2.00% $500
2019 0.35% 2.25% $500
2020 0.40% 2.50% $500

This is good news for what has been an oversubscribed D.C. SREC market, though it will have a negative impact on facilities across the region that will not be registered by January 31, 2011. Facilities that are registered and included after any changes are made will benefit from inclusion in the D.C. SREC market which should see a rebound in pricing. Unlike the unsuccessful efforts of Pennsylvania earlier this year to exclude out-of-state facilities, this effort by D.C. has been done with the consideration of the solar owners that have committed to solar on account of the opportunity to sell SRECs in D.C. Regardless of the merits of a move to a closed SREC market, the inclusion of previously registered facilities is a crucial aspect of any changes that are made.

Note: It is still too early to tell if this Bill will pass. It is highly unlikely that it would be passed before January 31. Therefore it is unclear what the deadline will be if/when such a bill were to pass. Anyone considering submitting an application to the D.C. market that should file one directly with the D.C. Public Service Commission. Instructions can be found on our State Certifications page.

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DC Bill introduced to limit out-of-state facilities

Solar Thermal SRECs in DC – Update

Friday, November 12th, 2010

The Washington D.C. Public Services Commission has recently clarified the requirements associated with registering Solar Thermal facilities to be eligible for the D.C. SREC market.

Moving forward, all eligible systems must be certified by the Solar Rating and Certification Corporation (SRCC). Specifically, the system has to be SRCC OG-300 certified.

The Washington D.C. Public Services Commission has indicated that any changes to the eligibility requirements would have to be made by the legislature, not the public services commission.

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Solar Thermal SRECs in DC – Update

Solar Capacity in the SREC States in 2010

Wednesday, July 28th, 2010

SRECTrade’s State of the SREC Markets in 2010
The New Jersey, Pennsylvania and Delaware Energy Years came to a close on May 31, 2010.  The following is a report of the solar capacity in megawatts (MW) certified and registered to create SRECs in all states at that time.

Solar generators by state located: This table is based solely on the location of the facility and does not include multiple state listings. All facilities must have been registered by May 31st, 2010.
Volume by state

As you can see New Jersey has by far the largest amount of solar installed and eligible for SRECs with 146 MW. Pennsylvania is a distant second at 17 MW.  Meanwhile, Ohio and Illinois are third and fourth respectively, however of the 16 MW in Ohio, 12 come from one facility and of the 10.1 MW in Illinois, 10 come from one facility. Delaware and Maryland both have sizable markets at around 6 MW each. Volumes in other state are much smaller since there is no local SREC market.

Solar generators by size: Projects certified for SREC markets range in size from as small as 0.5 kW to as large as 12 MW, however, only 20 out of the 7,700 projects are over 1 MW.  Of those 20 projects all are well below 5 MW, with the exception of a 10 MW facility in Illinois and 12 MW facility in Ohio. The lack of multi-MW facilities in the SREC markets is a function of both the complexity involved and constraints on demand. The only state SREC market today with any legitimate appetite for multi-MW facilities is New Jersey.

Solar generators by state eligibility: Because some states accept out-of-state SRECs, the in-state supply listed above differs from the total supply available to buyers in that state.  For instance, Ohio’s market also includes facilities located in PA, WV, KY, IN, and MI.  The table below lists the total solar capacity in megawatts eligible for each SREC market, along with the percent of the market that is sourced in-state.  Note: many facilities will be counted multiple times in this table since they are eligible in several states. For example, the 10 MW facility in Illinois is eligible in both DC and PA.

Thurs Table 2 final cropped

In Ohio 89.6% of the market is in-state SRECs. Some of our customers have asked why in-state Ohio SRECs do not sell at a premium because of the 50% in-state requirement. The reason is that, as you can see, buyers are not having difficulty meeting the 50% requirement with the large supply of in-state SRECs. In the future as the requirements increase, in-state SRECs could be harder to come by and may indeed sell for more than out-of-state SRECs.

Interpreting the data: One important thing to notice is that the 2010 Capacity Requirement column details the capacity required to be sustained throughout the entire energy year. The Volume column shows the capacity registered through May 2010. For example, New Jersey needed approximately 160 MW of capacity running on average from June 2009 through May 2010 in order to meet the 2010 SREC requirement. The state is actually farther away from the 160 MW capacity mark than the 145.69 MW volume would suggest.  Capacity in New Jersey grew approximately 65 MW over the course of the year and so there were probably only enough SRECs created to meet approximately 110-115 MW of the 160 MW requirement. That requirement increases in the 2011 Energy Year to approximately 260 MW. For more information on the growth of the New Jersey market and any other state market, please visit our page devoted to State SREC Markets.

Assumptions used in calculations: Solar capacity required is based on 2007 Department of Energy electricity sales figures, assuming a 1.5% growth rate. The resulting solar megawatt-hours required (i.e. SRECs) are converted to megawatt capacity requirement at a rate of 1200 MWhs per MW.

Solar Capacity in the SREC States in 2010

New York bill to create NY SREC program

Friday, June 4th, 2010

The New York state legislature has proposed a renewable portfolio standard with a solar carve out. Bill No. A11004 in State Assembly and Bill No. S7093 in the State Senate (jointly know as New York Solar Industry Development and Jobs Act of 2010) would require electric suppliers to purchase SRECs for 0.05% of their electric sales 2012, increasing gradually to 2.50% in 2025.

New York has traditionally used solar rebates and utility level solar incentives and is now considering in light of their success in states like New Jersey and Pennsylvania.

The SREC requirement proposed for NY are similar to those enacted in NJ and MD although NY is a significantly bigger population and power consumer. This RPS would dramatically increase the demand for solar renewable energy credits and take some of the pressure of the markets like DC that are currently the only home for the SRECs produce by solar PV installations in New York State.


New York bill to create NY SREC program

Solar Thermal SRECs in DC

Thursday, May 13th, 2010

SRECTrade recently began registering solar thermal facilities in Washington DC and North Carolina.  The North Carolina program is in the final stages of being setup and we will provide more information when it is available.  Meanwhile, we’ve already sold our first solar thermal SRECs in the DC market at $290.  Here are some guidelines and information in regards to the requirements to register solar thermal systems in Washington DC:

Are solar thermal SRECs valued the same as solar photovoltaic SRECs sold in auction?
Yes, in DC and NC, solar thermal facilities can be approved to generate SRECs that have the same value to buyers purchasing to meet state compliance requirements.  Any auction for SRECs in DC will include solar PV and solar thermal SRECs sold at the same price.

What if my facility is not eligible in Washington, DC or North Carolina?
Both DC and NC allow out-of-state facilities to qualify, so many states are eligible to sell into these markets.  If your state is not eligible to sell into DC or NC, then the RECs produced by your facility have no value to buyers in the state compliance markets (i.e. our buyers).  You may still however be able to find ways to sell the RECs in voluntary or non-solar compliance markets – also known as generic REC markets.  There are companies out there that may help.

What else should I know about selling SRECs as a solar thermal facility?
Keep in mind the DC SREC market is a relatively small market and could someday be oversubscribed.  We are hopeful that the market for solar thermal SRECs will grow beyond DC as other states follow suit, however, as with any markets, there are risks associated with the market value of SRECs in DC.

What are the requirements for reporting production and generating SRECs?

Residential:
System must be SRCC-300 rated.  Here’s the link to the approved systems if you don’t already have it: http://securedb.fsec.ucf.edu/srcc/annual_search.  DC will used the energy saved in kWh as your generation for the year.  For example, a 2400 kWh system would receive 200 kWh per month and once the accumulation hits 1000kWh an SREC will be credited to their account

Commercial:
1.  Displaces < 10,000 kWh per year – can use SRCC 300 rating, SRCC-100 panel rating, or use an OIML meter
2.  Displaces > 10,000 kWh per year – must use OIML approved meter

Here are the exact details of the requirements from the Clean and Affordable Energy Act of 2008:

(1) For nonresidential solar heating, cooling, or process heat property systems producing or displacing greater than 10,000 kilowatt hours per year, the solar systems shall be rated and certified by the SRCC and the energy output shall be determined by an onsite energy meter that meets performance standards established by OIML.
(2) For nonresidential solar heating, cooling, or process heat property systems producing or displacing 10,000 or less than 10,000 kilowatt hours per year, the solar systems shall be rated and certified by the SRCC and the energy output shall be determined by the SRCC OG-300 annual system performance rating protocol applicable to the property, by the SRCC OG-100 solar collector rating protocol, or by an onsite energy meter that meets performance standards established by OIML; and
(3) For residential solar thermal systems, the system shall be certified by the SRCC and the energy output shall be determined by the SRCC OG-300 annual rating protocol or by an onsite energy meter that meets performance standards established by OIML.”.

Hopefully this clarifies the solar thermal process in Washington DC.

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Solar Thermal SRECs in DC