Key Changes:
1. The number of SRECs required will dramatically increase
2. The SACP which sets a ceiling price for SRECs will be raised to levels competitive with other states
3. The municipal utilities that have been exempt thus far will now be required to comply

For more information, please see our previous post on the Delaware SREC Bill or our newly updated Delaware SREC page.

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.

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.

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.

Key Changes:
1. The number of SRECs required will dramatically increase
2. The SACP which sets a ceiling price for SRECs will be raised to levels competitive with other states
3. The municipal utilities that have been exempt thus far will now be required to comply

The alternative compliance payment (ACP) an energy supplier must pay if failing to meet the solar requirement will also increase following this bill being signed into law. The solar ACP will strengthen from $250 to $400 per missed SREC, with this payment increasing to $450 if an ACP were paid in the previous year and to $500 if non-compliance continued for a third year. This will effectively raise the ceiling on SREC prices in Delaware to $400+.

The legislation also adds a premium to SRECs produced by systems created by in-state resources.  An additional 10% credit toward meeting RPS requirements is granted for any SREC obtained from a facility constructed or installed with at least a 75% in-state workforce.  The same credit is granted for systems with at least 50% of their components manufactured in Delaware.  These provisions together will likely lead to a premium on SRECs from in-state solar systems.

Though well-intentioned, it is unclear how the state will track this premium given that it essentially will result in two markets for SRECs… one for normal SRECs and one for the special “Made by Delaware Labor” SRECs.  Other states have tried to implement various types of multipliers with limited success and more likely resulting in more trouble than their worth.  However, it could be particularly useful in giving an advantage to local Delaware companies on the larger projects that face tough competition from well-capitalized out-of-state developers.

Nonetheless, the intent is clear: Delaware wants to develop a strong solar industry in-state.  This is a positive sign for the solar market there and in some ways a contrast to other states.  SREC markets have a variety of benefits to a state.  Besides a move to renewable energy, a properly setup program will also encourage the development of a commercial and residential solar industry.  In some cases,  like New Hampshire and North Carolina, the state will benefit from the former, but it doesn’t necessarily mean a boost to the latter.

Overall this is a huge win for the Delaware solar industry.  Today, most of our customer base from Delaware sells their SRECs in the PA or DC markets.  It will be great for them to know that their future SRECs will likely be sold in their home state!  Delaware now joins Maryland and New Jersey who have also passed recent legislation directed at strengthening their respective SREC markets.

The full text of SS1 for SB119 can be found here.

Details can be found here: Delaware SREC Program

Chart numbers are based on 2007 electricity sales into Delaware assuming a 1.5% annual growth rate

So in summary, the reason you might see prices higher than $250 is because buyers are forced to pay a higher fine if they have previously fallen short on their requirement.

DC Facility Rejections
We previously reported that a facility was rejected out of New York state and have learned that the application provided that the electricity was not capable of being transmitted into the PJM region. The DC PSC was subsequently unable to get clarification in order to approve the facility.

A second facility in New York has also been rejected because there was “no basis to conclude that the facility generates electricity consumed within the PJM Interconnection region.”  We are currently seeking clarity on how these determinations are made and will post them when we have more information.  In the meantime, here are some details:

DC rule 945-E-1764 (http://www.dcpsc.org/pdf_files/commorders/dcmr15/Chapter29.pdf) defines a renewable energy credit as “a credit representing one megawatt hour of electricity consumed within the PJM interconnection region that is derived from a tier 1 renewable source, a tier 2 renewable source, or a solar source that is located:

“In the PJM Interconnection region or in a state that is adjacent to the PJM Interconnection region.”

The same document describes New York as an “Adjacent PJM State” and the New York Independent System Operator (NYISO) as an “Adjacent Control Area”.  The crux of the issue seems to be the wording “consumed within the PJM interconnection region”.  Electricity flows bidirectionally between PJM and NYISO every day, the amount varying based on supply and demand in the two ISOs.  An electron generated in NYISO clearly can’t be tracked (Heisenberg and all), so there is no way to know if a given electron generated by the grid-tied solar installation makes its way into PJM and is consumed. In fact there is no way to know if a given electron generated by any installation in any “Adjacent PJM State” makes its way to PJM and is consumed there, although it is possible that any electron generated in an adjacent PJM state will. Going even further, an electron generated by a system located in DC might actually be consumed outside PJM! As we see it, this leaves two choices on how to interpret the DC RPS rules. Either every grid tied generator in an “Adjacent PJM State” could be delivering their electrons to be consumed in PJM and therefore all are eligible to create DC renewable energy credits, or none can prove that their specific electrons where consumed in PJM and so none are eligible.

How far back will DC accept SREC generation?
We also get questions about systems that were installed prior to the application date in DC. Customers and installers will ask how far back DC will count solar generation for SRECs. DC will only count SRECs created in the current energy year (same as calendar year) as long as generation is inputted before the last business day in January. This means that, as of this blog post, any generation for a facility in 2009 will not count. Only generation from January 2010 onwards will be eligible for the creation of SRECs.

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In Pennsylvania, for example, a resident within the PJM region can apply for certification in the Pennsylvania SREC program.  If your system is convered in this map, you can sell SRECs to PA!

Washington, DC is similar to Pennsylvania in that both allow SRECs from anywhere within the PJM region, however DC will also qualify facilities that are eligible to deliver their electricity into the region. This may include facilities in states that are adjacent to the PJM region such as New York or Wisconsin.

Ohio is another state that allows SRECs from out of state. In that specific case, the utilities are limited to buying 50% from out of state and only from states within the region that are contiguous: Pennsylvania, West Virginia, Kentucky, Michigan and Indiana.

Washington, DC is similar to Pennsylvania in that both allow SRECs from anywhere within the PJM region, however DC will also qualify facilities that are eligible to deliver their electricity into the region.

For these reasons, it is important to know what constitutes the PJM region to determine whether or not you qualify.  Here is a map of the region, along with the retail electricity companies who are served by PJM.

This is great news for market participants in Delaware. Although most sellers will register their facilities out of state in Pennsylvania and DC where higher Alternative Compliance Payments (ACP) lend to higher SREC prices, it is important that Delaware establish its own SREC market to support the growth of the industry in-state without relying on legislation of neighboring states to do so.

On a related note, Delaware’s Governor Jack Markell has proposed the extension of the state RPS by 10 years through 2029, increasing the total requirement from 20% to 30% of electricity for renewables.  In addition to the proposed expansion of the program to include all of Delaware’s electricity suppliers (not just Delmarva Power), this could also be an opportunity to increase the ACP in Delaware.  We will see!

1. Understand SRECs: For a deeper understanding of what SRECs are and how the programs work, visit our SREC Program page.

2. Find out where you are eligible to sell your SRECs: Your state may or may not have a program, however your ability to sell your SRECs into other states could have a significant impact on the value of your SRECs. You may be eligible to get your system certified in many state programs, regardless of if your state has one or not. Everyone should check our Cross-Listing post to see the states in which they may be eligible for certification.

3. Get your system installed: SRECTrade works with several installation companies. In addition, you should be able to sign up for the EasyREC service through your installer. If they do not offer the service, then feel free to contact us directly.

4. Enroll with SRECTrade: SRECTrade provides two options. If you sign up for the EasyREC service, we handle everything else including submitting your state certification applications, creating your SREC tracking account and automating the sale of your SRECs in our auction.

If you do not sign up for EasyREC, here are the additional steps:

4a. Get your system certified by your state: Once the system is installed, it is now ready to be certified by your state and any other states in which you are eligible. You can find out more on where you are eligible and how to apply on the Cross-Listing page. Every state handles this process differently, but we recommend beginning the application as soon as possible, before your installation is complete.

4b. Set up your SREC tracking account: Every state or region will use a different system for creating and tracking the SRECs. The Mid-Atlantic states use GATS, North Carolina uses NC-RETS, Massachusetts uses NE-GIS. If you opt to manage your own SRECs, you will need to have a tracking account with one of these registries. Once you have SRECs in that account, you can then post them in our auction.

4c. Create an account online with SRECTrade: This is the simplest step of all. Complete the online form to create your account and when your SRECs are available in your tracking account, log into your SRECTrade account, select the “Orders” link and place an offer to sell your SRECs.

5. Understand the timing: After you initially sign up, it will take a few months before you begin receiving payments. For example, if your system goes online on January 1st, your January generation will be recorded on February 1st. Your first SREC(s) will be actually credited to your account on March 1st. They would then be sold in the March auction, so your first payment would come in late March. After that, payments will come as SRECs are generated. Also note: some systems operate on a quarterly basis, rather than monthly.

As these processes are refined, we will continue to update this post. Please feel free to contact us any time at 877-466-4606 if you have any questions.

SREC State Registration Information:

Delaware

To get a Delaware state certification number, your installation must be located in DE. You must apply to become an Eligible Energy Resource. The link for the application is here.  For more information, go to the Delaware Public Service Commission.

Contact:
Delaware Public Service Commission
861 Silver Lake Boulevard
Cannon Building, Suite 100
Dover, DE 19904
Main: (302) 736-7500
Toll-Free: (800) 282-8574
Fax: (302) 739-4849

District of Columbia

Eligible to states within and adjacent to the PJM Region. For information on the DC registration process, see DC State Certification Instructions.

Contact:
Dorothy Wideman
Commission Secretary
Public Service Commission of the District of Columbia
1333 H Street, N.W
2nd Floor West Tower
Washington, D.C. 20005

Maryland

To register in Maryland, your solar installation must be in MD and you must complete and file an application for certification as a Solar Renewable Energy Facility (REF) with the Public Service Commission. The link to the application is here.  For more complete details on the process, see Maryland SREC Registration Details.

New Jersey

New Jersey is a closed market, therefore only SRECs produced in New Jersey are eligible. New Jersey residents can apply for state certification at the New Jersey Office of Clean Energy’s website.

Contact:
New Jersey’s Clean Energy Program
c/o Conservation Services Group
75 Lincoln Highway, Suite 100
Iselin, New Jersey 08830
Phone: 866-NJSMART (866-657-6278)

North Carolina

North Carolina is still in the early stages of implementing an SREC program. The state is still accepting applications for a REC tracking system through December 15, 2009.  More information can be found on the North Carolina Utilities Commission website. A sample application can be found here.

Contact:
Chief Clerk
North Carolina Utilities Commission
4325 Mail Services Center
Raleigh, NC 27699-4325

Ohio

Utilities in Ohio are allowed to procure 50% of the SRECs from out of state facilities. However, these states must be contiguous with Ohio (PA, MI, IN, KY, WV). Instructions and forms required for Ohio certification can be found here: Application for Certification as an Ohio Renewable Energy Resource Generating Facility

Contact:
Public Utilities Commission of Ohio
Email: AEPS@puc.state.oh.us
Toll-Free: (800) 686-PUCO (7826)
Phone: (614) 466-3292 (in Columbus area)
Fax: (614) 752-8351
180 East Broad Street
Columbus, Ohio 43215
Directions to the PUCO

Pennsylvania

Utilities in Pennsylvania are allowed to buy out of state SRECs from solar generators in the PJM region to meet the Renewable Portfolio Standard. If you are interested in selling in PA, you need to get your solar system registered.  For a detailed explanation of the process with screenshots see our most recent post on Pennsylvania State Certification Registration Process.

Contact Info:
Dina M. Deana
Pennsylvania AEPS Program Manager
Clean Power Markets, Inc.
Phone: 1-877-AEPS-773 (1-877-237-7773)
Fax: (610) 444-9213
Email: paaeps@cleanpowermarkets.com