Archive for the ‘Massachusetts’ Category

SREC-II Regs Filed – SRECTrade Webinar: Monday, 4/21 @ 2 pm ET

Posted April 11th, 2014 by SRECTrade.

On Friday, 4/11/2014, the Massachusetts Department of Energy Resources formally announced the submission of revisions to the Massachusetts RPS Class I regulations which set aside and define the Massachusetts SREC programs. As expected, the revisions call for the effective start of the next MA SREC program (commonly referred to as SREC-II) on 4/25/2014. A link to the announcement is here. SRECTrade will host a webinar covering the start of the MA SREC-II program on Monday, 4/21/2014 at 2 pm ET.

Webinar registration is open to anyone. Please register for the webinar by clicking this link or the image below.

The MA-SREC II program is the next iteration of the Massachusetts solar initiative to reach 1,600 MW of installed solar capacity. Massachusetts sited solar facilities that are not yet qualified for the SREC-I program by April 25th will be subject to the rules of the new SREC-II program. This webinar will cover the mechanics of SREC-II and adjustments made to the SREC program application process.

We look forward to seeing you on the webinar!

MA SREC-II blog image

SREC-II Announcements from the DOER – March 17, 2014

Posted March 19th, 2014 by SRECTrade.

On March 17th, 2014, Stakeholders in the Massachusetts DOER’s Solar Carve-Out received an email with two key announcements regarding the proposed revisions to the RPS Class-I Regulation.

1)    That last week, the Joint Committee on Telecommunications, Utilities, and Energy submitted their comments to the DOER on the proposed revisions. These comments were broken up into nine items, which are summarized below.

2)    That the draft of the Solar Carve-Out II Program’s Assurance of Qualification Guideline was released for public comment and review. This is particularly relevant to systems that are qualified under the “Managed Growth” market sector. The DOER will be accepting comments on the draft Guideline through March 28, 2014. All comments should be emailed to DOER.SREC@state.ma.us and should contain the subject line “Assurance of Qualification Guideline Comments.”

Summary of the Committee’s comments:

Item 1: Price Volatility

Following the initial boom in solar development, spurred on by SRECs trading near the Alternative Compliance Price, SREC prices have dropped significantly. The Committee believes that the Managed Growth concept will be a useful “tool for reducing volatility in the market which should benefit both retail electric suppliers and solar facility owners.”

Item 2: Cost

The Committee supports the 1600 MW solar goal by 2020, but believe it is “important that the program is designed to achieve its goal at low costs” to the consumers. Gradually lowering the ACP and Clearinghouse Auction-II fixed prices reduces the risk of high cost to ratepayers funding these programs.

SREC Factor: Different factors to different market segments in order to more accurately match costs for each of these segments. “Considering the falling costs of solar,” committee members “encourage the DOER to review the SREC Factor Guideline even earlier than…March 31, 2016.”

Competition Imperative to Assure Low Costs: With its Guidelines, the DOER has left the possibility for competition open. The committee believes that “competition can be effective at lowering costs.”

Achieving Transmission and Distribution (T&D) Benefits to Maximize Cost Effectiveness: There is little incentive for solar growth at locations on the distribution grid that would provide maximum benefit to the grid, and ultimately ratepayers. The Committee Encourages the DOER to work closely with solar developers, utilizing tools such a solar maps, and to advocate for integrated distribution programs, which could lower total program costs.

Item 3: Equity Between Market Sectors

Under SREC-I, ground and roof projects were worth the same, but the latter cost significantly more per unit of capacity. SREC Factor helps correct the bias towards the larger systems.

Item 4: The Solar Carve-Out and Net Metering

The committee “hopes that…Solar Carve-Out II…[takes] into account the limitations on aggregate net metering capacity.” Additional changes may be necessary “to continue the growth of solar in Massachusetts.”

Item 5: Third-Party Ownership versus Direct Ownership

Though “Third-Party Ownership structures have provided…homeowners, businesses, municipalities and other government entities…with access to solar and lower energy costs,” the committee also recognizes the benefits of homeowners and businesses owning their systems outright. The committee strongly supports the DOER’s ACP-funded financing program to “help address barriers to direct ownership.”

Item 6: Class I RPS Eligibility for non-SREC GIS Certificates

SREC Factor ostensibly limits the demand for SRECs associated with the installed capacity target by generating a set portion of an SREC per megawatt-hour. However, the committee sees no reason why the portion of solar electricity that does not fall under Solar Carve-Out II Renewable Generation Attributes also does not fall under RPS Class I Renewable Generation Attributes.

Item 7: Restricting Market Sector C to a Single Parcel of Land

The section stating that arrays with a capacity less than 650kW are also eligible for Market Sector C does not specify that this capacity should be measured as the total capacity of Solar Carve-Out II units on a single parcel of land. The committee believes there ought to be such a provision: without one, larger projects that should be restricted to managed growth may inappropriately be able to access Sector C.

Item 8: Access to Solar for Non-Profit Institutions

Although non-profits make up 15% of the Commonwealth’s employment, “less than 3% of solar projects have been developed by or on behalf of non-profits.” The DOER should institute changes to the proposed regulations or to the SREC Factor guidelines to help remedy this discrepancy.

Item 9: Pre-2010 Solar Systems

Although early-adopters of the commonwealth rebate program may have received larger rebates than late-comers, many of these aggregators “have abandoned their solar REC aggregation” due to the scarcity of Class I REC-generating facilities in Massachusetts, and consequent difficulty of selling their attributes. The committee would like to the DOER consider offering Solar Carve-Out I or II eligibility to pre-2010 systems.

Further/In-depth reading:

The Original Email

DOER’s website

The Joint Committee on Telecommunications, Utilities, and Energy’s full comments 

RPS Solar Carve-Out II Assurance of Qualification Guideline

DOER Draft of SREC-II Regulations

The Renewable Energy Portfolio Standard – Class I

 

 

 

 

DOER Submits SREC-II Proposal to the Massachusetts Legislature

Posted February 20th, 2014 by SRECTrade.

On Thursday, February 13th, the DOER announced that a new draft of the Massachusetts RPS Class I Regulations 225 CMR 14.00 was formally submitted to the Joint Committee on Telecommunications, Utilities, and Energy for review. The draft contains key language for the creation of the touted SREC-II program. Please find the announcement letter from the DOER here. The filing is available here. Given this step and further formal review requirements that the revised regulations must undergo over the next few weeks, it is our understanding that the SREC-II program will likely become effective  in early Q2 2014.

The DOER’s letter also clarifies that non-operational projects qualified under SREC-I may not also be qualified under SREC-II, without first withdrawing SREC-I qualification.

MA DOER Hosts Public Hearing on SREC-II Program

Posted January 28th, 2014 by SRECTrade.

On Friday, January 24, the Massachusetts Department of Energy Resources (MA DOER) held a public hearing in Boston. The meeting allowed MA solar stakeholders to provide feedback and comments on the proposed SREC-II regulations. Additionally, the DOER will be accepting written comments on the SREC-II legislation. All written comments are due by this Wednesday, January 29th at 5 p.m. ET. Comments can be submitted electronically to DOER.SREC@state.ma.us or to Michael Judge, via mail to the Department of Energy Resources, 100 Cambridge Street, Suite 1020, Boston, MA 02114.

For an overview of the draft regulations, see our blog post here: DOER Releases Draft of SREC-II Regulations. As it currently stands, it appears the SREC-II program will be put in place as early as the beginning of Q2 2014. We’ll continue to provide more information on the development and implementation of the program as it becomes available.

DOER Releases Draft of SREC-II Regulations

Posted January 7th, 2014 by SRECTrade.

225 CMR 14.00 Renewable Portfolio Standard Class I Regulations

On January 3, 2014, the Massachusetts Department of Energy Resources (DOER) filed revisions to the 225 CMR 14.00 Renewable Portfolio Standard Class I regulation. The email announcement is available here. The redlined, unofficial version of this draft is available on the DOER website, and the official version of the draft regulation will be published in the Massachusetts Register on January 17, 2014. This filing begins the formal rulemaking process.

The primary objectives of the revisions are twofold: 1) to establish the second phase of the Solar Carve-Out program (the SREC-II program); and 2) to revise the RPS Class I program to address previously identified needs to improve the program design. Next stages for the rulemaking process and a few excerpts of the draft are detailed below.

I. Continuation of Rulemaking Process

A. Public Hearing

The DOER will hold a public hearing on January 24, 2014 from 1:00 to 3:00 pm to receive oral and written comments on the proposed regulations. The hearing will be held at the Gardner Auditorium of the Massachusetts State House in Boston, MA. Parties interested in presenting oral testimony at the hearing are requested to provide written copies of their testimony.

B. Written Comments

Per the DOER: Written comments will be accepted beginning on January 3, 2014 and ending at 5:00 pm on January 29, 2014.  Please submit written comments electronically to DOER.SREC@state.ma.us or to Michael Judge, via mail to the Department of Energy Resources, 100 Cambridge Street, Suite 1020, Boston, MA 02114.

II. Selected Excerpts

A. Eligibility for SREC-II

Section 14.05(9)(b) specifies that a Solar Carve-Out II (SREC-II) Renewable Generation Unit must have a Commercial Operation Date on or after January 1, 2012 and must not be qualified as a Solar Carve-Out Renewable Generation Unit (that is, qualified under the SREC-I program). Section 14.06(4)(c) states that the RPS Effective Date for SREC-II facilities shall be the Commercial Operation Date or the first day following the calendar quarter in which the Unit receives its Statement of Qualification (see Part C. below), whichever is earlier.

Like SREC-I facilities, SREC-II facilities will be issued 40 quarters of SREC-eligibility, based on the SREC factor times the number of MWh generated. The SREC factor assigned to a Unit in its Statement of Qualification (SQA) shall remain its SREC factor for its entire 40 quarters of eligible generation of Solar Carve-Out II Renewable Generation Attributes. Furthermore, the DOER shall complete a review of the SREC Factor Guideline no later than March 31, 2016 to take into consideration market data and analysis as well as external changes in state and federal policies and global markets. Any changes made by these guidelines shall apply to Sectors A-C for units qualified on or after January 1, 2017 and will apply to projects seeking capacity for the Managed Growth Sector in 2018. 14.05(l)4, 5.

chart

 

Any excess of the SREC factor accumulated during the 40 quarters will be retired by NEPOOL-GIS. After 40 quarters of SREC-II eligibility, the system will cease to produce SREC-IIs and will begin producing Class-I credits for 100% of the MWh that the system generates. 14.05(9)(k).

Any solar photovoltaic facility larger than six MW in capacity installed on the same parcel of land and meeting all other requirements under SREC-II may qualify only for RPS Class I Renewable Generation Attributes. 14.05(9)(a). The SREC-II program capacity cap is the aggregate eligible capacity, in MW, of Solar-Carve Out II Renewable Generation Units qualified by the Department equal to 1600 MW minus the Solar Carve-Out Program Capacity Cap. 14.02.

B. Eligibility for SREC-II in the Managed Growth Sector

SREC-II facilities in the Managed Growth Sector will be eligible for qualification subject to several provisions, including annual capacity blocks, which will be announced no later than June 30 of each subsequent Compliance Year for the Compliance Year two years in the future.

  • For Compliance Year 2014, the annual capacity block shall be 26 MW;
  • For Compliance Year 2015, the annual capacity block shall be 80 MW. 14.05(m).

C. Procedure for Applying for an Assurance of Qualification & Financing Opportunities

The DOER will issue a full guideline outlining the process for providing Assurance of Qualification, though the draft revisions did not specify where or when these guidelines will be available. However, the revisions do specify that the content of these guidelines will be subject to stakeholder review and comment.

Section 14.05(o) details that the DOER shall grant an Assurance of Qualification for SREC-II facilities that have either:

  1. been granted the approval to interconnect to the grid by their local distribution company; or
  2. have provided evidence of the following:
    (a)  an executed Interconnection Service Agreement (ISA) with the distribution company; and
    (b)  adequate site control, interest, or other contractual right to construct the system at the location specified in the ISC; and
    (c)  all required governmental permits and approvals to construct the system, including building permits and notwithstanding any pending legal challenge(s) to such permits.

Section14.05(p) confirms that the DOER will establish a program utilizing ACP funds to enhance the availability of ownership financing options for SREC-II facilities. This program will be available for residential and other buildings that are owned by 501(c)(3) organizations who are incorporated under state law as not-for-profit corporations.

D. Solar Credit Clearinghouse Auction-II (SCCA-II)

Below is an overview of the Solar Credit Clearinghouse Auction under the SREC-II program. For the most part, the rules and process are similar to how the auction is run under SREC-I.

The Solar Credit Clearinghouse Auction-II for SREC-II shall be held as follows, pursuant to the draft regulations Section 14.05(9)(f)-(j):

  1. The first auction will be held each year on or before July 31.
    SCCA-II will be available for deposits between May 16 and June 15, inclusive of these dates. A 5% fee will be assessed for all SCCA-II clearinghouse prices, pursuant to the fixed price schedule available below. All SREC-II attributes deposited into SCCA-II will be eligible for two additional years.

    chart acp

    If the first auction clears, then the total amount of re-minted auction-II account generation attributes (SRECs) will be distributed to the bidders in a pro-rated manner based on their bid volume.

  2. If the first auction does not clear, then the DOER will void the auction and conduct a second auction within three business days of the first auction. The SRECs deposited into this auction will be issued eligibility for three subsequent compliance years from the year in which they were generated.
  3. If the second auction does not clear, then the DOER will void the auction and recalculate the Massachusetts Solar Carve-Out II Minimum Standard to adjust the demand before conducting a third auction, which will be held within three business days of the second auction. If this third auction does not clear, then the demand will be reallocated on a pro rata basis, and the excess will be returned to sellers with the previously-issued three year eligibility. These SRECs will be ineligible for future auctions.

E. Renewable Energy Portfolio Standard & Compliance Obligation Formula

The compliance obligation formulas remains the same as under 14.07(2)(d): For each subsequent Compliance Year (CY), the total compliance obligation shall be equal to the total compliance obligation from the previous Compliance Year (CY-1), plus the difference between the Solar Carve-Out Renewable Generation Attributes projected to be generated for the previous Compliance Year and the Solar Carve-Out Renewable Generation Attributes actually generated for the Compliance Year two years  prior (CY-2) which is multiplied by 1.3, plus the number of Solar Carve-Out Renewable  Generation Attributes from the Compliance Year two years prior banked as provided under 225 CMR 14.08(2), plus the number of Solar Carve-Out Renewable Generation Attributes from the Compliance Year two years prior deposited into the Solar Credit Clearinghouse Auction Account.

Total Compliance ObligationCY = Total Compliance ObligationCY-1 + [Total SRECs Generated (projected)CY-1 - SRECs Generated (actual)CY-2] x 1.3 + Banked VolumeCY-2 + Auction VolumeCY-2

The SREC-II Minimum Standard will not apply to the portion of load-serving entities’ (LSEs) energy sales that were subject to electricity contracts signed prior to the implementation of the program, provided that the LSE in the party to the contract provides the DOER with evidence of such contract. 14.07(3)(b).

Section 14.07(3) establishes the SREC-II Minimum Standard, which will be calculated and announced by the DOER not later than August 30 of the preceding Compliance Year as specified in the Section. 2014 and 2015 demand has already been established:

  • For Compliance Year 2014, the total compliance obligation is 41,279 MWh of SREC-II generation by 85 MW of SREC-II capacity across the sectors. 14.07(3)(c).
  • The total compliance obligation for Compliance Year 2015 is 161,958 MWh, generated by 230 MW of SREC-II capacity across the sectors. 14.07(3)(d).

For each subsequent Compliance Year (CY), the total compliance obligation shall be determined by the DOER as equal to the sum of the following quantities of generated and projected SREC-IIs:

  1. Installed SREC-II Supply (installed facilities);
  2. Qualified but not Installed SREC-II Supply (facilities that have been initiated but are not yet online);
  3. Projected New Supply (based on prior growth trends by market sectors and annual capacity blocks, such that cumulative installed capacity does not exceed the cumulative installed capacity target for the end of the year as follows);max capcity table
  4. Rollover Volume (those SREC-IIs that remain eligible for compliance from re-minted SCCA-II generation and banked SREC-IIs); and
  5. Third Round Auction Volume Doubling (in the case of a third round SCCA-II).

Section 14.07(3)(g) assures that the DOER will provide a clear and precise methodology by which it will calculate the quantities set forth above and the Compliance Obligation.

After 2020, the RPS Class I Minimum Standard shall increase by 1% per Compliance Year unless modified by law. 14.07(4).

As the rulemaking process continues, we will provide updates and additional analysis on this blog.

 

DOER Commissioner Mark Sylvia’s SREC-II Preview

Posted December 20th, 2013 by SRECTrade.

The Massachusetts SREC market is in the process of switching from the existing SREC-I program to a yet to be officially proposed SREC-II program.  At a meeting held on Friday, 12/13/2013, Mark Sylvia, the Commissioner of the Massachusetts Department of Energy Resources (DOER),  presented a preview of some items we should expect to find in the DOER’s official SREC-II proposal.

In August 2013, the DOER  presented a draft proposal for the SREC-II program with the intention to incorporate feedback from stakeholder groups before presenting a final proposal sometime by the end of 2013. Now that 2013 is nearly done, it’s likely that the formal proposal will not emerge until early January 2014. Once the SREC-II proposal is issued there are several regulatory hoops that the proposal must go through before the program can be put in place. We blogged about the SREC-II implementation timeline in a previous post here and expect the process to take 100 days or more.

Key items learned from Mark Sylvia’s presentation

Items that have not changed from the draft proposal

1) SREC factors and Market Sectors - Depending on project size and other considerations projects will be able to produce SRECs at different rates. Smaller projects receive more SRECs on a per MW-hr basis than larger projects. For example, a residential project will receive 1 SREC for every MW-hr produced, whereas a landfill sited project might receive 0.8 SRECs per MW-hr. SREC factor will be determined by Market Sectors as described below.

Market Sectors

2) Declining Solar Credit Clearinghouse Auction (SCCA) pricing and Alternative Compliance Payment (ACP) rates - The SCCA is the MA market’s price floor mechanism. In SREC-I the SCCA is fixed at a price of $300/SREC, but the SCCA will drop from $300 to $285 starting in 2017 and then drop again on a yearly basis with SREC-II. The SREC-II ACP rate will start at $375 in 2014 and 2015 and decline, beginning in 2016, as shown in the table below.

ACP Schedule

Items that HAVE changed from the draft proposal

1) No Forward SREC Minting
Originally the DOER proposed that residential projects should be eligible to create 10 years worth of SRECs  at the onset of a project. This provision was removed, presumably amid concerns about how to properly track and incentivize SREC production after the upfront issuance and payment is made.
 
2) No Competitive SREC Factor 
All projects are to be assigned fixed SREC factors determined by Market Sector. In the DOER’s draft proposal, projects under the Managed Growth Market Sector (>500 kW and less than 67% on site electricity usage) would competitively offer for a spot to be eligible for the SREC-II program by adjusting the SREC factor. Projects with the lowest SREC factors would be given a spot in the eligible projects queue. This is no longer the case.
 
3) New Grant Program for Directly Owned Residential Facilities 
The Commonwealth Solar II grant program will stay in place until another $30 million program can be implemented using Alternative Compliance Payment (ACP) funds to support direct ownership. Presumably 3rd party leasing / PPA entities will not be able utilize the funds. It was previously expected that the current grant program would end with the sunset of SREC-I.
 
How Much Longer?
In-line with our expectations, the presentation announced the RPS revisions for SREC-II should be filed any day. A public hearing and comment period will follow as well as committee review processes. The DOER projects that the rules will become effective by the end of Q1 2014. We will continue to keep a close eye on the rule making process and provide updates as they are available.

MA DOER Posts SREC-I Project Extension Guidelines

Posted November 15th, 2013 by SRECTrade.

On November 14, 2013, the Massachusetts Department of Energy Resources (DOER) posted the official, final project eligibility extension guidelines for SREC-I (current SREC program) qualified projects >100 kW in size.*

The official extension guidelines can be found here and the DOER’s email announcing the guidelines can be found here.  Without an extension, the deadline for installing SREC-I eligible projects >100 kW is December 31, 2013. Projects are eligible for an extension if they can prove they have incurred 50% of the cost to construct by 12/31/2013. Extension forms must be filed with the DOER no later than January 13, 2014.

*Projects less than or equal to 100 kW DC in capacity do not need to file for an extension. These projects are eligible for SREC-I provided that they can prove interconnection and have submitted complete program Statement of Qualification Applications (SQA) by the day before the effective date of the start of the SREC-II program. It is expected that the effective date of SREC-II will likely occur sometime on or before the end of Q1 2014.

 

Massachusetts Webinar Recording – Presented by SRECTrade and Mike Judge of DOER

Posted November 14th, 2013 by SRECTrade.

SRECTrade and Mike Judge of the DOER present the current status of the Massachusetts SREC-I program.  Additionally the webinar covers the regulatory process that the SREC-II program proposal must udergo before the SREC-II program may start. The webinar recording can be watched by clicking the image below.

November 2013 MA SREC webinar

 

Massachusetts SREC-I and SREC-II program updates

Posted November 5th, 2013 by SRECTrade.

The eagerly awaited MA  SREC-II program promises to keep the MA solar industry in over-drive, but when will it start and what happens between now and then? We’ve previously noted in our blog and bulletin emails sent to installers that moving forward SREC-I is separated into two applicant categories. There is still uncertainty about the SREC-II program design and timeline for its implementation, but we know that it may be implemented as early as Q1 2014.

SREC-I Projects 100 kW and Smaller

Projects 100 kW and smaller are eligible for the SREC-I program provided that they are installed and officially interconnected (permission to operate in hand) before the effective date of SREC-II. Our current understanding is that the effective date of SREC-II will likely be sometime after January 2014.

SREC-I Projects Larger than 100 kW

Projects eligible for SREC-I that are not fully interconnected by 12/31/13 must apply for an eligibility extension. Projects are eligible for extensions if they have spent at least 50% of the estimated project construction cost by 12/31/13.

SREC – I extension documents can be found here. Projects registered with SRECTrade should return these documents to us no later than Friday, 12/13/13 to guarantee that SRECTrade can send them to the DOER and confirm their acceptance.

SREC-II Is Still Not Official

We expect the DOER to formally propose the SREC-II program in early November 2013. Once this is done the proposal must undergo several formal review steps including a public comment period and legislative review period. Given these steps we anticipate that the review process will take 100 days or more. Assuming this timeline, the SREC-II program would be effective in February 2014.

Also, be aware that the formal proposal will likely include deviations from the DOER’s initial draft proposal that was submitted in August.

Here are the steps required prior to implementation of the SREC-II program.

Step #1 – File formal SREC-2 proposal with the MA Sec. of State

Step #2 – Hold Stakeholder Meeting in Boston (within 21 days of formal filing)

Step #3 – Assess public comments and post comments on DOER website

Step #4 – Submit Proposal to the Joint Committee on Telecommunications, Utilities, and Energy

Step #5 – Post to DOER website Joint Committee comments (30 days required)

Step #6 – Submit final draft to MA Sec. of State

Step #7- SREC-2 Program effective start (likely 14+ days after final submission to Sec. of State)

Massachusetts SREC Webinar, Thursday, 11/14 at 2 pm EST.

Posted November 5th, 2013 by SRECTrade.

SRECTrade will host a webinar covering the Massachusetts SREC market on Thursday, 11/14/2013 at 2 pm EST. Sign up for the webinar by clicking here or the image below.

What the Massachusetts SREC webinar will cover:

  1. The close out of the SREC-I program
  2. New SREC-II program rules and steps required for SREC-II to be implemented*
  3. Current Massachusetts SREC supply analysis
  4. Current Massachusetts SREC pricing

*UPDATE- November 12, 2013:  It is unlikely that the DOER will formally propose SREC-II in time for Thursday’s webinar. The DOER is now targeting the end November to formally post the SREC-II proposal. We will still cover the timeline for implementing SREC-II once it is formally proposed.

November 2013 MA SREC webinar