Archive for the ‘Massachusetts’ Category

MA DOER Issues Draft Guidelines for Revised SREC-II Market Factors

Posted August 16th, 2016 by SRECTrade.

Yesterday, the Massachusetts Department of Energy Resources (DOER) announced its draft Guidelines relating to the revised SREC factors for the Solar Carve-out-II program. The draft Guidelines can be found on the DOER’s website, which includes the Adjusted SREC Factor Guideline Draft as well as draft versions of the 225 CMR 14 Solar Guideline – Extension Guideline and Detailed Construction Costs Form. The draft Guidelines follow the July 1, 2016 promulgation of the Emergency Regulations. As the DOER explains, “Recognizing that a long-term sustainable solution will take time to develop and that many projects are in advanced stages of development, the emergency regulation is intended to address market uncertainty and establish a smooth transition from SREC-II to the next incentive program.”

The draft Guidelines contain both clarification on construction timeline extensions and the revised SREC factor guidelines. For construction extensions, as provided in 225 CMR 14.05(9)(s)(4), a qualified Solar Carve-out II Renewable Generation Unit that is larger than 25 kW DC that has not received the authorization to interconnect or permission to operate by January 8, 2017, and cannot demonstrate that it is mechanically complete by January 8, 2017, can request a construction deadline extension to May 8, 2017. Extensions will be provided if a project can demonstrate to the satisfaction of the DOER that the project has expended at least 50% of its total construction costs by January 8, 2017.  The 225 CMR Solar Guideline – Extension Guideline sets forth the procedures and requirements for Solar Carve-Out II Renewable Generation Units that seek this extension. The draft Guideline also includes an Excel Spreadsheet and Attestation Form to be completed and submitted to the DOER.

The new SREC factors, as provided for by 225 CMR 14.05(9)(l)5, shall apply to any Solar Carve-out II Renewable Generation Unit that meets the following criteria:

  1. Nameplate capacity less than or equal to 25 kW and authorized to interconnect after January 8, 2017; or
  2. Nameplate capacity greater than 25 kW that receives an extension pursuant to 225 CMR 14.05(9)(s)4.a.

The Adjusted SREC Factor Guideline provides new SREC Factors for each SREC Market Sector. Under the revised Guideline, all projects that meet the criteria outlined above shall receive an SREC Factor that is reduced by approximately 15-20% from current values. A comparison of the current SREC Factors and the revised SREC Factors is provided below:

Screen Shot 2016-08-16 at 5.13.34 PM

 

Screen Shot 2016-08-16 at 5.13.42 PM

The DOER invites comments on the draft Guidelines through August 22, 2016 at 5:00PM. Comments can be sent to DOER.SREC@state.ma.us with the subject line “SREC-II Guideline Comments”.

Additional information concerning the SREC-I & SREC-II markets in Massachusetts can be found on our Massachusetts market page.

MA DPU Establishes Net Metering “Notification Date” as September 26, 2016

Posted August 3rd, 2016 by SRECTrade.

On July 29, 2016, the Massachusetts Department of Public Utilities (the “DPU”) issued its Order Announcing Notification Date and Directives to Distribution Companies in its proceeding under 16-64-D, establishing the Net Metering “Notification Date” as September 26, 2016. Pursuant to Chapter 75 of the Acts of 2016D.P.U. 16-64-C, and as confirmed by this Order, there are three strict criteria that must be met for a private net metering project to receive net metering credits under the old regime:

  1. Submission of an Application for Cap Allocation (ACA) to the Massachusetts System of Assurance of Net Metering Eligibility (System of Assurance) for a net metering cap allocation prior to the Notification Date of September 26, 2016 by 2:00pm;
  2. Receipt of confirmation from the System of Assurance Administrator that the application (ACA) is complete; and
  3. Receipt of a ACA cap allocation by January 8, 2017.

In its Order, the DPU determined that “the best option to result in a smooth transition to a stable and equitable solar net metering market” was to align the timing for transition to the new net metering credits policy with the Massachusetts Department of Energy Resources (DOER)’s SREC-II program. In selecting September 26, 2016 as the “Notification Date”, the DPU calculated the maximum amount of time that could be required to obtain a cap allocation on or before January 8, 2017, which was determined to be 70 business days. In addition, the September 26 date is exactly 60 calendar days after the Order’s announcement of the Notification Date. In consideration of these two timelines, the DPU determined that this date would provide enough time for systems to plan for, apply for, and receive a net metering cap allocation under the existing framework.

For more information on the current and new net metering regulation in the state of Massachusetts, please visit our previous blog post on the topic.

MA DOER Announces Solar Credit Clearinghouse Auction Results

Posted July 29th, 2016 by SRECTrade.

Today, the Massachusetts Department of Energy Resources (DOER) announced that both of the 2015 Solar Carve-out (SREC-I) and Solar Carve-out II (SREC-II) auctions have fully cleared in the first round.

Preliminary results for the SREC-I auction included 41 unique bidders submitting a total bid volume of 49,886 – more than sufficient demand to clear the available auction volume of 1,898 SRECs. Similarly, the results for the SREC-II auction included 9 unique bidders submitting a total bid volume of 112,252, which cleared the available auction volume of 67,046 SREC-IIs.

SCCA Auction Results3

The DOER and EnerNOC continue to certify and finalize the auction results, and will publicize more details on the final results on the SREC-I and SREC-II auction webpages next week.

MA DOER Announces Preliminary 2017 Compliance Obligation

Posted July 25th, 2016 by SRECTrade.

Friday, July 22, 2016, the Massachusetts Department of Energy Resources (DOER) announced the preliminary 2017 Solar Carve-out (SREC-I) and Solar Carve-out II (SREC-II) Compliance Obligations and Minimum Standards. Customarily, the DOER estimates these values prior to administering the Solar Credit Clearinghouse Auction each year. The final 2017 Minimum Standards will be announced on or before August 30th, after both the SREC-I and SREC-II Auctions have concluded.

Solar Carve-out (SREC-I)

Notably, the DOER projects that the final 2017 Compliance Obligation for the SREC-I program will be approximately 783,181 MWhs and that the Minimum Standard will be approximately 1.6313%. These values will be increased to 785,077 MWhs and 1.6352%, respectively, if the SREC-I auction does not fully clear in the first two rounds. The 2017 Minimum Standard for load under contracts signed before to June 28, 2013 will be 0.9861%.

The DOER published a resource outlining its calculation of the preliminary SREC-I Minimum Standard.

Preliminary 2017 Compliance Obligation SREC-I Table

Solar Carve-out II (SREC-II)

Regarding the SREC-II Program, the DOER established a baseline Compliance Obligation and Minimum Standard that would have applied to Retail Electricity Suppliers had the RPS Class I Emergency Regulation not been filed on April 8, 2016; these suppliers are exempt from any additional obligations resulting from the expansion of the SREC-II Program Capacity Cap.

To calculate this baseline Minimum Standard, the DOER first determined the expected MWh/year that would have resulted had the SREC-II Program Capacity Cap remained 947 MW by:

  1. Identifying the percentage shares of MW currently qualified under each SREC-II Market Sector;
  2. Multiplying these percentages by the original 947 MW SREC-II Program Capacity Cap;
  3. Multiplying these totals by (1) their respective SREC Factors, (2) a 13.51% expected capacity factor, and (3) 8,760 hours/year.

The DOER then summed these values and combined the auction volume and banked SREC-II volume from the 2015 Compliance Filings, resulting in a baseline Compliance Obligation of 1,102,311 MWhs and a Minimum Standard of 2.2960%. These values will be increased to 1,169,357 MWhs and 2.4357%, respectively, if the SREC-II auction does not fully clear in the first two rounds.

Preliminary 2017 Compliance Obligation SREC-II Table 2

Additionally, the DOER calculated the preliminary 2017 SREC-II Compliance Obligation and Minimum Standard for load under contracts signed after May 8, 2016 – 1,496,188 MWhs and 3.1164%, respectively. These values will be increased to 1,563,234 MWhs and 3.2561% if the SREC-II auction does not fully clear in the first two rounds.

Preliminary 2017 Compliance Obligation SREC-II Table

The DOER also published a resource outlining its calculation of the preliminary SREC-II Minimum Standard.

Solar Credit Clearinghouse Auctions

The first rounds of the SREC-I and SREC-II Solar Credit Clearinghouse Auctions are scheduled for July 29, 2016. A second and third round will be held as needed the following week should these auctions not fully clear.

The DOER has also provided slight updates to the volumes of SRECs available in the Auctions: 1,896 in SREC-I and 67,046 in SREC-II.

SRECTrade will continue to monitor the proceedings of the Solar Credit Clearinghouse Auctions and will report the outcomes of the Auctions once the results become readily available.

Massachusetts SREC Update – July 2016

Posted July 18th, 2016 by SRECTrade.

With the recent promulgation of the DOER’s Emergency Regulations regarding SREC-II, last Friday’s issuance of Q1 2016 SRECs, and the upcoming SCCA auction, there has been plenty of activity in Massachusetts’ SREC markets.  The last few months have been a dynamic period in terms of state market policy as the state regulatory agencies determine how to move forward following the conclusion of the SREC-II program. This period has also seen growth in both project applications and installations.

On June 22nd, 2016 the Massachusetts DOER updated their list of generation units with Statements of Qualification (SQA). While this list gives us a good view into the  bulk of applications that have been processed, the correlation between the number of SQAs issued and the facilities that will ultimately be built is less clear.  While the data shows a dramatic increase in volume, only time will tell whether that growth will actually translate into new operational assets by year end.

You can find our most recent Massachusetts SREC-II capacity update presentation here.

The chart below shows the historical growth in cumulative size of the SREC-II market since 2014:

MA Cap

Represented by the green bars to the right, the pool of assets that have been issued SQAs but are not yet operational is significantly larger than all of the qualified and operational assets that have been registered since the market’s inception.  This dynamic has created a state-wide “sprint to the finish” as developers work to get as many projects as possible under the SREC-II umbrella before the program deadline on January 8, 2017.  Consequently, MA2016 SREC-II supply is far outpacing the RPS demand.

 

2016S&D

In 2015, the SREC-II program was oversupplied by approximately 70,238 credits, or 57.3% of the exempt load obligation of 122,617.  That surplus is carried over to 2016, and added to the 615,413 projected SREC generation to come to a total supply of 685,651 SRECs.  2016 projected SREC generation is based on holding the average TTM build rate of 26.5 MW/month constant through the year, and then applying seasonally adjusted SREC production factors.   With a 2016 exempt load adjusted obligation of 327,471, we project an oversupply of approximately 358,180 or 109.4% of the demand obligation.

We will continue to update these projections as new information becomes available.  In the coming weeks we will expect to see official results from the 2015 SCCA auction and a new demand number for the 2017 compliance obligation.  All of these will have material impacts on the projection for future supply and demand balance in the MA SREC-II market, and we will be sure to issue new analyses as that information is made public.  As always, feel free to reach out to your SRECTrade brokerage desk point of contact to further discuss this analysis.

 

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Massachusetts Solar Credit Clearinghouse Auction – Summer 2016

Posted July 7th, 2016 by SRECTrade.

On July 6th, the Commonwealth of Massachusetts Department of Energy Resources (DOER) announced that EnerNOC Inc. has posted the Auction Notice and Qualification Application for this year’s Solar Credit Clearinghouse Auction (SCCA) to the Solar Renewable Energy Credits (SREC-I and SREC-II) Auction Announcement Website. The SCCA serves as a price support mechanism for the Massachusetts SREC programs. In over-supplied years (when more SRECs are available than required), buyers are incentivized to purchase SRECs through the SCCA, if they believe that the SCCA price is at or below the potential future price of the SRECs. You can read more about the SCCA here. The 2016 SCCA is scheduled to begin on Friday, July 29th.

SREC Volume

This year, the DOER will conduct Solar Credit Clearinghouse Auctions for both SREC-I and SREC-II certificates. The volumes of certificates available for purchase through each auction are as follows:

MA15 SREC-I: 1,898 certificates
MA15 SREC-II: 66,440 certificates

Multi-tiered Auction

The auction will be divided into two tiers of bidders. The Tier I bidders will consist solely of Retail Electric Suppliers with Renewable Portfolio Standard (RPS) compliance obligations. Up to fifty percent (50%) of the total auction volume will be reserved for Tier I bidders. If bid demand exceeds fifty percent (50%) of the total auction quantity, awards will be made on a pro-rata basis. If there is insufficient demand, each bid received will be awarded and the remaining quantity of SREC-I and SREC-IIs will be made available to Tier II bidders. Tier II bidders consist of all entities, including any Tier I bidders with unfulfilled bids from Tier I. The remaining auction quantity after the Tier I awards have been made will be allocated on a pro rata basis to all Tier II Bidders, as has been done in all prior auctions.

Minimum and Maximum Financial Security Requirements

The separation of Retail Electric Suppliers from Non-Retail Suppliers also stands in the auction’s Minimum and Maximum Financial Security Requirements. For only the SREC-II Auction, all Non-Retail Electric Suppliers without RPS compliance obligations must post at least $10,000 in financial security to participate in the SREC-II Auction. For both the SREC-I and SREC-II Auctions, Retail Electric Suppliers with RPS compliance obligations will be credited an amount of security commensurate with the volume of electric load that they served in 2015. Both Retail Electric Suppliers posting above their credited security and Non-Retail Electric Suppliers without RPS compliance obligations can post an amount no greater than the amount required to purchase ten percent (10%) of the total auction volume. Non-Retail Electric Suppliers in the Commonwealth of Massachusetts without RPS compliance obligations cannot bid on and will not be awarded SREC-I or SREC-IIs in excess of ten percent (10%) of the total auction volume.

Key Dates & Bidder Webinar Registration

Friday, July 8, 2016 – Bidder webinar to review auction process and the Qualification Application
To register for the webinar, click here.
Wednesday July 13, 2016 – Bidder Qualification Application due
Friday, July 29, 2016 – First auction takes place

Questions regarding the SCCA can be directed to the Auction Manager email account at: masrecauctionmanager@enernoc.com.

Massachusetts SREC-II Emergency Regulation Promulgated

Posted July 5th, 2016 by SRECTrade.

On April 8th, the Massachusetts Department of Energy Resources (DOER) filed an Emergency Regulation with the Secretary of the Commonwealth to extend the SREC-II program listed under 225 CMR 14.00. Following this announcement, a public hearing was held to welcome comments on the proposed changes to SREC-II. After reviewing all submitted written comments and oral testimony, the DOER made the following modifications to the Emergency Regulation and filed the final version with the Secretary of the Commonwealth on June 17th. As of July 1st, 2016, the final version of the regulation is officially promulgated and in effect.

Below is a summary of changes made in the final Emergency Regulation:

1. Extension beyond January 8, 2017.

The first change is an extension beyond January 8, 2017 for projects that can demonstrate 50% of their construction costs have been spent by that date. The extension is similar to a regulatory provision that was part of the transition between SREC-I and SREC-II. In response to comments requesting an extension, the DOER made changes to the regulation that will allow for all projects that can demonstrate 50% of construction costs have been expended by January 8, 2017, to receive a four month extension to their construction deadline through May 8, 2017. A Guideline clarifying the process by which projects will be required to document these expenditures will be issued by DOER later this year.

2. Reducing SREC Factors.

The second modification to SREC-II consists of reducing SREC Factors for any projects qualified under an extension to the program. In an effort to reduce the cost impact of any further expansion, the DOER made changes to the regulation such that all systems with a “nameplate capacity equal to or less than 25 kW and receives an authorization to interconnect after January 8, 2017 or that qualifies for an extension under 225 CMR 14.05(9)(s)4.a will receive a lower SREC Factor…”. The DOER will revise the SREC Factor Guideline to reduce SREC Factors for these projects on or before August 31, 2016.

3. Technical Edits and Clarifications.

The final change to SREC-II includes technical edits and clarifications. The DOER made several changes correcting minor technical errors and language inconsistencies in the regulation.

In the same announcement, the DOER reported that it will be conducting Solar Credit Clearinghouse Auctions for both the SREC-I and SREC-II programs this summer. The DOER will make a separate announcement with more details and details regarding the volume of certificates deposited into each auction account sometime this week.

To view the original email from the MA DOER, click here.

MA Department of Public Utilities Clarifies Net Metering Regulation

Posted May 25th, 2016 by SRECTrade.

Please note this blog post has been revised from the original May 24, 2016 post.

On Wednesday, May 18th, the Massachusetts Department of Energy Resources (DOER) notified the Department of Public Utilities (DPU) of its intent to file its determination that the 1,600 Megawatt (MW) threshold will be met on or about June 1, 2016 and requested that the DPU clarify whether facilities with private cap allocations on or before the “Notification Date” will receive the current net metering credits or the new Market Net Metering Credits. Under the recently enacted Chapter 75 of the Acts of 2016, this determination sets into motion DPU’s charge to establish a “Notification Date”, which will serve as a deadline for systems that are under the private net metering cap to be interconnected or allocated under the cap in order to receive the current net metering credits. Furthermore, the DOER requested that the DPU clarify its Emergency Net Metering Regulations and assure those facilities in receipt of net metering cap allocations on or before the Notification Date that their projects will receive net metering credits at current rates and will not receive Market Net Metering Credits (which are effectively equal to 60 percent of the retail rate). Prior to the DOER’s request, the uncertainty around the Notification Date deadline left private-cap projects in advanced stages of construction at risk of receiving Market Net Metering Credits if they failed to be interconnected by the Notification Date, creating project financing concerns.

In its May 19th Order Clarifying Emergency Net Metering Regulations, the DPU formally recognized that systems obtaining a private net metering cap allocation are “on the path toward interconnection”, since these allocations are assurances that a system will receive net metering services upon authorization to interconnect. In clarifying its policy on net metering credit eligibility, the DPU extended retail rate credit eligibility for projects that receive a private cap allocation by the Notification Date, even if those projects are not yet interconnected. Resultantly, for the duration of the Emergency Net Metering Regulations, Solar Net Metering Facilities that are interconnected or in receipt of a private cap allocation from the System of Assurance by the Notification Date shall receive retail rate net metering credits (that is, Net Metering Credits as defined in 220 C.M.R. § 18.04(1) and (5)).

This interpretation of eligibility will remain in effect only for the effective period of the Emergency Net Metering Regulations, and it is highly probable that the Notification Deadline will be set by the DPU for a date later than June 1, 2016. Following notice by the DOER that the 1,600 MW cap has been allocated, the DPU will solicit comments on the Emergency Net Metering Regulations and related issues, conduct a public hearing, and enact Final Net Metering Regulations effective July 29, 2016. Accordingly, it is possible that the Notification Deadline will be set as July 29, 2016 or possibly later than this date.

In accordance with the Order, facilities under the private net metering cap that fail to meet the Notification Date deadline will receive Market Net Metering Credits. Residential projects 10 kW and smaller on single-phase circuits, or systems under 25 kW on 3-phase circuits, will be exempt from the new rate structure under Sections 7 and 8 of the Act and are guaranteed retail remuneration rates. To be clear, facilities under the public net metering cap will continue to receive net metering credits at the current rates and will not be impacted by this Notification Deadline. For more information on current net metering and other solar legislation in Massachusetts, please visit our previous blog post on the topic here.

Massachusetts Raises Caps; Passes Net Energy Metering Bill

Posted April 17th, 2016 by SRECTrade.

On April 11, Governor Baker signed into law Chapter 75 of the Acts of 2016. The law, which was passed with an emergency preamble to have immediate effect, raises the net metering cap by 3% for private and public solar projects and will reduce the current retail remuneration rate to the wholesale rate for commercial and community solar projects once the state hits its 1600 MW solar target. Residential projects 10 kW and smaller on single-phase circuits, or systems under 25 kW on 3-phase circuits, will be exempt from the new rates under Sections 7 and 8 of the Act. Finally, the Act will permit utilities to charge solar project owners a minimum bill to cover their fixed costs.

The immediate effect of the Act will enable the stalled solar industry in Massachusetts to restart in the short term, but the Act is far from a comprehensive solution to establishing long-term, sustainable policies for solar in the Commonwealth. With the new cap estimated to be reached in some territories within a few weeks, the pressure remains on the Legislature to continue discussions on the future of solar in the state.

The Act is the result of compromise between and among the Senate, the House of Representatives, and Governor Baker. Following an impasse of the chambers’ and Governor’s respective bills last summer and into the fall, the Legislature was able to reconcile H.4173 and S.1979, passing the bill in each chamber with nearly unanimous approval. The lone “Nay” was asserted by Rep. Jonathan Hecht (D), who voiced his worry that devaluing net metering credits was a step in the wrong direction for the Commonwealth. “I’m afraid if we do lower net metering rates by that large amount, it means many solar projects simply will not get built[]”, Hecht said.

With the devaluation of net metering rates, stakeholders will expect the value to be made up elsewhere to ensure the financial viability of solar projects. Following the SREC-II Emergency Regulations issued by the DOER last week, it is clear that the DOER is working on the next phase of the state’s solar incentive program to fulfill their obligations under Section 11 of the Act. Sustainable Energy Advantage, LLC (SEA) has been engaged to assist in conducting analysis in evaluation of the next program, and stakeholders will have the opportunity to participate in the design and implementation of the next phase of the program.

Thanks in large part to the state’s net metering policies, former Governor Patrick setting the state’s 1,600 MW target, and the successful SREC-I and SREC-II programs, the robust Massachusetts solar industry now employs more than 15,100 people. Today, the state ranks sixth in installed solar capacity, with more than 1,020 MW of solar installed.

 

Massachusetts SREC-II Emergency Regulation Filed: April 8, 2016

Posted April 11th, 2016 by SRECTrade.

On Friday, April 8, 2016 (the effective date), the Massachusetts Department of Energy Resources (MA DOER) announced it filed emergency regulation with the Secretary of State’s office. The regulation was submitted to address the current uncertainty in the solar industry and facilitate a smooth transition from SREC-II to the next incentive program. Although this emergency regulation is effective immediately, it can only remain in effect for 90 days pending a full DOER rule-making proceeding. Information on next steps in the emergency regulation process is still forthcoming, including public hearings and public comment submission deadlines.

Notably, the emergency regulation implements the following:

  • Extends SREC-II eligibility to all systems greater than 25 kW constructed by January 8, 2017; 9 months from the effective date
  • Extends SREC-II eligibility to all systems less than or equal to 25 kW interconnected by the start of the next incentive program
  • Implements compliance exemption for all electricity supply contracts signed within 30 days of the effective date
  • Ensures SREC-II will run through 2027

In regard to systems greater than 25 kW, the emergency regulation grants Statements of Qualification dated April 8, 2016, to all systems that have an existing Assurance of Qualification or that have submitted an application. The retention of granted Statements of Qualification is dependent on systems demonstrating (1) authorization to interconnect or (2) proof of construction to the DOER by January 8, 2017.

Reiterating the note above, in regard to systems less than or equal to 25 kW, all applications that demonstrate authorization to interconnect by the start of the next incentive program will be qualified under the SREC-II program.

In close, the DOER noted that development of the Commonwealth’s next solar energy incentive program is underway. Sustainable Energy Advantage, LLC (SEA) has been engaged to assist in conducting analysis in evaluation of the next program. Additionally, the DOER will work with market participants to solicit feedback as the program is designed and implemented.

SRECTrade will continue to monitor the status of the emergency regulation and provide updates regarding the future of Massachusetts’s next solar incentive program. We look forward to watching the state continue to structure competitive market based solutions, similar to those previously utilized, to continue its position as a national leader of deploying distributed solar technologies.