Posts Tagged ‘legislation’

Massachusetts Governor Baker Releases Net Metering Bill to Rival Senate Bill

Posted August 13th, 2015 by SRECTrade.

Shortly before its summer recess, the Massachusetts Senate passed Amendment 18 to S. 1973 in a voice vote on July 23. Two weeks later, on August 7, 2015, Massachusetts Governor Charlie Baker released a net metering bill to rival S. 1973.

Both the Senate Bill and the Governor’s Bill address the net metering caps that are currently causing a slow-down in the Commonwealth’s solar development, and look to former Governor Patrick’s goal for the Commonwealth to install 1,600 megawatts of solar energy in Massachusetts by 2020. Earlier this year, the Baker-Polito Administration announced its support of the goal to achieve 1,600 MW by 2020. Accordingly, both S. 1973 and the Governor’s Bill propose to raise the net metering caps to meet the goal of 1,600 MW by 2020.

Under Amendment 18 to S. 1973, the Senate calls for raising the caps to 1,600 MW, and eliminating the caps thereafter (the elimination of the caps would apply to solar net metering facilities, with the exception that the maximum amount of generating capacity eligible for net metering by a municipality or other governmental entity shall be 10 megawatts), but the bill would do little else to change the value of a net metering credit. In addition to addressing the caps, the Amendment calls for Massachusetts regulators to “develop a solar incentive program to encourage continued development of solar…” with the goal of “develop[ing] a sustainable long-term framework that effectively balances promoting clean energy and costs to ratepayers,” to be implemented after the 1,600 MW target has been reached. Unfortunately, the Senate bill also attempts to limit the potential options for future programs, without much consideration for allowing the stakeholder process to consider all of the policy options presented by the Task Force in its Final Report (see below).

In contrast, Governor Baker’s Bill would substantially reduce the value of net metering credits in the Commonwealth. For solar projects over 10 kW on single phase, or projects over 25 kW on 3-phase, the value of net metering credits will be the average monthly clearing price in ISO-NE (that is, the wholesale retail rate). This would be a drastic change from the current value, which includes the value of all wires charges, such as distribution, transmission and transition charges. For other specific facilities, including municipal or other governmental entity (“MOOGE”) facilities, facilities for low-income off-takers and community shared solar facilities, the value of net metering credits will be based on the utility’s basic service kW charge, and will also exclude wires charges. The result of this exclusion in both categories is the value of credits being cut nearly in half. But like the Senate Bill, the Governor’s Bill also calls on Massachusetts regulators to “establish a solar incentive program for the development of distributed solar generation beyond 1,600 [MW] by solar photovoltaic facilities connected to a distribution or transmission system, which shall be a statewide program.”

Both the Senate Bill and the Governor’s Bill draw upon the recommendations from the Net Metering and Solar Task Force. The Net Metering and Solar Task Force was a group established last fall by the Massachusetts Legislature under Ch. 251 of the Acts of 2014, Section 7. The Task Force was responsible for reviewing the “long-term viability of net metering and develop recommendations on incentives and programs to support the deployment of 1600 MW of solar generation facilities in the commonwealth.” In its Final Report, the Task Force encouraged the Commonwealth to develop a solar incentive framework that would satisfy eight different program attributes, including promoting the orderly transition to a stable, equitable and self-sustaining solar market, and relying on market-based mechanisms and/or price signals as much as possible to set incentive levels such that the program would be readily adaptable to changing market conditions, all while minimizing costs, incentivizing diverse development, and promoting investor confidence. The Task Force cautiously qualified its recommendations by stating that “[t]he selection of a path for modeling is not an indication that a majority, or indeed any, of the Task Force members would like to see that path implemented,” and encouraged the DOER and DPU to lead a “comprehensive and transparent solar benefit/cost study to determine the value of impact of solar in Massachusetts” so that the Massachusetts Legislature, DOER, and DPU could more thoroughly evaluate the options presented by the Task Force, including the potential for an SREC III program to follow the highly successful SREC I and SREC II programs.

When the Legislature returns from its summer recess this Fall, the Joint Committee on Telecommunications, Utility and Energy will be confronted with the formidable task of reconciling these rival bills alongside the recommendations from the Net Metering and Solar Task Force, in order to help shape the future of solar in Massachusetts.

NJ Governor Christie Signs Bill to Increase Solar Requirements

Posted July 23rd, 2012 by SRECTrade.

Today, New Jersey Governor Chris Christie signed into law legislation to increase the state’s solar goals by amending the Renewable Portfolio Standard (RPS). Both Senate Bill 1925 and Assembly Bill 2966 were passed on June 25, 2012. The bill, which attempts to address the state’s SREC oversupply, adjusts the Renewable Portfolio Standard (RPS) Solar requirements by amending the following:

1) Solar RPS Requirements Increased beginning in Reporting Year 2014: Beginning June 1, 2013 the market will see an increase in SREC requirements, shifting the state’s solar goals from a fixed megawatt hour requirement to a percentage based requirement. Although the requirements increase in the near term, later dated requirements decline over the current solar goals.

2) New Solar Alternative Compliance Payment (SACP) Schedule: Beginning in the 2014 energy year, the SACP will be reduced to $339 declining to $239 by 2028.

3) Grid Supply Projects Capped at 80 MW Per Year in 2014-2016: In 2014, 2015, and 2016 only 80 MW of aggregated grid supply solar can be installed. Certain exemptions for landfills and parking lots have been made. The capacity of a single project shall not be greater than 10 MW.

4) SREC Life Extended to 5 Years: SRECs will be eligible to meet compliance obligations the year in which they are generated and the following four compliance periods.

5) Rules Set for Public Entity Net Metering Aggregation: The bill implements regulations for aggregate net metering for public entities such as schools, counties, or other municipal agencies.

NJ Solar RPS in 2014 and Beyond: Summary of Solar % Requirements and SACP

The charts below demonstrate the % Solar Requirements set under the new bill as well as the proposed SACP schedule. It is important to note that the existing 2012 and 2013 reporting year (RY) requirements do not change under this piece of legislation. RY2012 and RY2013 have an SREC requirement of 442,000 and 596,000 SRECs, respectively. Additionally, the SACP for RY2012 and RY2013 are $658 and $641, respectively.

Slow Down New Jersey, You’re Installing Too Much Solar – The NJ SREC Market Looking Forward

On July 19, 2012, the New Jersey Office of Clean Energy estimated installed solar capacity to be 831.6 MW as of 6/30/12. This represents an increase of approximately 29 MW from the prior month. Also, the state’s solar project pipeline increased by approximately 30 MW to 590 MW as of 6/30/12 from 560 MW the month prior.

As of the latest SREC issuance data in PJM GATS, we estimate the RY2012 market to be oversupplied by approximately 230,000 SRECs. Taking into consideration this oversupply and installed capacity through 6/30/12, the RY2013 market will be oversupplied by more than 600,000 SRECs without any new projects installed in the remaining compliance period (July 2012 – May 2013).

Looking forward to 2014, the state needs to realize a substantial reduction in installed solar capacity on a monthly basis to see the market come into balance in future reporting years. Using similar forecast cases from our prior analysis, Case 1 shows oversupply by approximately 97,000 SRECs through 2015. This is under a scenario in which install rates decline to 18.8 MW/month; representing half of the last twelve month (LTM) average – now 37.6 MW/month through June 2012.

The legislation signed into law today is a step forward to allow ongoing development of solar projects in the Garden State. This bill was needed to ensure companies servicing the NJ solar market are able to continue forward, existing solar projects see some stabilization, and rate payers are protected from excessively high SREC prices. The future development of projects needs to be monitored closely by all stakeholders as this bill requires current install rates to decline in the near term for the market to come into balance with the revised RPS requirements in future reporting years.

A Break In The Clouds? – NJ Legislature Passes S1925/A2966

Posted June 26th, 2012 by SRECTrade.

Introduction

On June 25, 2012, S1925/A2966, now aligned with each other, passed the New Jersey Senate and House. Next, the bill needs to be signed into law by the Governor, which given his recent public support is expected to be completed within the next couple weeks. The bill, which attempts to address the state’s SREC oversupply, adjusts the Renewable Portfolio Standard (RPS) Solar requirements by amending the following:

1) Solar RPS Requirements Increased beginning in Reporting Year 2014: Beginning June 1, 2013 the market will see an increase in SREC requirements, shifting the state’s solar goals from a fixed megawatt hour requirement to a percentage based requirement. Although the requirements increase in the near term, later dated requirements decline over the current solar goals.

2) New Solar Alternative Compliance Payment (SACP) Schedule: Beginning in the 2014 energy year, the SACP will be reduced to $339 declining to $239 by 2028.

3) Grid Supply Projects Capped at 80 MW Per Year in 2014-2016: In 2014, 2015, and 2016 only 80 MW of aggregated grid supply solar can be installed. Certain exemptions for landfills and parking lots have been made. The capacity of a single project shall not be greater than 10 MW.

4) SREC Life Extended to 5 Years: SRECs will be eligible to meet compliance obligations the year in which they are generated and the following four compliance periods.

5) Rules Set for Public Entity Net Metering Aggregation: The bill implements regulations for aggregate net metering for public entities such as schools, counties, or other municipal agencies.

Summary of the Legislation’s Solar % Requirements and SACP

The charts below demonstrate the % Solar Requirements set under the new bill as well as the proposed SACP schedule.

More Solar Now, Less Solar Later – How Does This Compare to the Current RPS Solar Requirements?

While S1925/A2966 increases the RPS requirements in the near term, by 900,000 or more SRECs each year in the 2014-2020 reporting years, beginning in 2024 the bill reduces the SREC requirements. The table below shows the current RPS requirements vs. the number of SRECs estimated to be required under the new legislation.

Oversupply Likely Through at Least 2014, Possibly Longer – What Does This Mean For the Market Moving Forward?

While increasing the RPS requirements is needed to address NJ’s current solar oversupply, the requirements implemented under S1925/A2966 do not necessarily put the market back into under supply. The days of SRECs trading up against the SACP at levels of $600+/SREC are long behind us for 2 reasons: 1) The SACP will naturally push pricing down to levels below $339 when it comes into effect in 2014 and 2) current installed capacity points to oversupply should the market continue at recent rates. This means that if the market is to see an under supplied scenario (i.e. a seller’s market), the amount of solar installed needs to slow down. We would naturally expect to see this take place given the removal of certain federal incentives and a decline in SREC prices, but this decline has been taking somewhat longer than expected in the first half of 2012 (i.e. likely a result of projects being wrapped up from the end of calendar year 2011).

The table below demonstrates the current RPS requirements vs. the estimated requirements under S1925/A2966 assuming no new additional capacity is installed after the NJ Office of Clean Energy’s May 31, 2012 capacity estimates.

It is important to note that the table above shows that regardless of the impact of the new legislation, the 2013 compliance period is oversupplied by approximately 575,000 at a minimum (i.e. the unlikely case of no build throughout the period).

Below, similar to our prior posts, 3 scenarios are analyzed. The first assumes future build continues at half of the last twelve month (LTM) average rate, 38.6 MW/month through May 31, 2012. The second assumes the market continues to build at its LTM average rate and the third case assumes install rates grow adding 1.5x the LTM average rate.

The table below shows the impact of the three scenarios presented above as compared to the estimated SREC requirements under S1925/A2966. If installation rates are able to decrease to half of the LTM average rate, the market will see a slight under supply beginning in 2014. Cases in which the market continues at current rates or increases above current monthly capacity installed show substantial oversupply in each of the periods forecast.

In conclusion, it is important that the solar industry recognizes that if this legislation is signed into law, it does not allow for the rate of installs to see continued growth. The bill merely helps address the oversupply by increasing the near term requirements and putting some limitations on larger scale solar projects. It will be necessary that all industry stakeholders track the market’s progress closely to clearly understand how supply is pacing relative to the SRECs required during that compliance period.

New Jersey Legislation Update: A2966

Posted June 7th, 2012 by SRECTrade.

***UPDATE: As of the close of June 7, 2012, the NJ legislature noted A2966 passed out of the Assembly Telecommunications and Utilities Committee. The bill will now move on to its second reading.***

On Thursday, June 7, 2012 at 10 a.m. ET the New Jersey Assembly’s Telecommunications and Utilities committee will review Assembly Bill 2966. A2966, sponsored by Assemblyman Chivukula, is the assembly’s version of S1925, which passed out of the Senate on 5/31/12; 23 (Yes), 9 (No), 8 (Not voting). While both bills propose to revise NJ’s Solar Renewable Portfolio Standards (RPS), A2966, proposes slightly different revisions as compared to S1925. For a detailed review of S1925, see our prior note here. Should A2966 pass out of committee, the bill will be voted on in the Assembly. If it passes out of the Assembly, A2966 and S1925 would have to be reconciled prior to its review by the Governor’s office before ultimately being signed into law.

Summary of A2966

Similar to S1925, A2966 proposes a few substantial changes that would influence New Jersey’s RPS requirements beginning in the 2014 compliance year (June 1, 2013 – May 31, 2014). The chart below demonstrates the proposed % based Solar requirement outlined in A2966 vs. S1925. Under A2966, the Solar RPS requirements would change beginning in the 2014 compliance year, with a requirement of 1.99% increasing to 4.63% by the 2028 energy year. Additionally, the second chart below shows the proposed Solar Alternative Compliance Payment (SACP) schedule in A2966 vs. S1925.

How Does A2966 Impact New Jersey’s Future SREC Requirements?

The table below shows the SREC quantities required under the current RPS versus the estimates required under the A2966.

Similar to S1925, A2966 takes the steps needed to prop up the NJ SREC market, but a closer look suggests that even if this bill is signed into law the market could continue to be oversupplied. The table below shows the current RPS and estimated requirements under A2966 through 2017. Both scenarios demonstrate what the markets look like given installed capacity through April 30, 2012, and assume that excess, eligible SRECs from prior periods are used to meet the compliance obligations in the current period. Under the current RPS requirements, assuming no new build, the market is oversupplied through energy year 2016. Applying these same figures to the estimated SRECs required if A2966 is implemented, the market is short approximately 198,000 SRECs in 2014 (the equivalent of approximately 165.0 MW operational all year long).

Although the requirements under the current installed capacity and proposed changes under A2966 put the EY2014 market at under supply with no new build, the likelihood of that is minimal. Over the last twelve months (LTM), through April 2012, the average MW installed per month has been 36.8 MW. That figure over the last 6 months has reached 46.6 MW/month. Given the recent historic build rates, we have analyzed 3 different scenarios in which the following cases are assumed:

1) Case 1 – shows half of the LTM average MW added per month throughout the course of the annual forecast periods;

2) Case 2 – shows the LTM average MW added per month remains the same throughout the annual forecast periods;

3) Case 3 – shows 1.5x the LTM average MW added per month throughout the annual forecast periods.

Note, for the purpose of obtaining an ending balance of MW capacity as of May 31, 2012, the table below assumes another 36.8 MW is added in the month of May 2012.

Under A2966, the market is less oversupplied or under supplied depending on the case displayed above. One of the main differences between the table above and our estimates under S1925, is that if installations slow down to half of the LTM monthly average rate, Case 1, the market would be oversupplied though 2015; whereas Case 1 under S1925 would see under supply in 2015. It is important to note that each case assumes all excess, eligible SRECs from the prior period are utilized to meet the current year RPS requirements.

As demonstrated in the scenario analysis, the market would need to substantially slow down current monthly build rates to allow supply to come in line with demand in the future RPS compliance periods. A2966 attempts to lessen the impact of oversupply, but even under the scenarios above, all three cases show oversupply through at least 2015. Additionally, the trade-off of an increased Solar RPS % comes at the cost of reducing the SACP. Thus, although the NJ solar industry can continue to build projects at a reduced rate, new installs will have to be underwritten with the understanding that less value will be derived from SRECs.

Note: Percentage based SREC requirements have been forecast based on EIA Report updated 11/15/11 “By End-Use Sector, by State, by Provider”. Projected SRECs required utilizes the most recent EIA electricity data applying an average 1.5% growth rate per forecast year. The state’s RPS Solar requirement is then multiplied by forecast total electricity sales to arrive at projected SRECs required. Projected capacity required is based on a factor of 1,200 MWh per MW in New Jersey.

Last minute push to revive Pennsylvania HB 1580

Posted May 21st, 2012 by SRECTrade.

**Update: As of this writing (Tuesday, June 12th) HB 1580 has not gone up for vote. However, the PA legislator extended the legislation session through the end of June, allowing for some hope that with enough grassroots pressure from supporters of the PA solar industry the bill will go up for vote. PASEIA encourages supporters of HB 1580 to continue to call into the offices of the PA House leadership. The applicable phone numbers are listed below. 

A coalition of solar industry groups led by PASEIA, SEIA, PennFuture and Vote Solar are making one last push to revive Pennsylvania House Bill (HB) 1580 before the close of the work week on Friday, 5/25. HB 1580 was first introduced in October 2011 by Rep. Chris Ross (R-Chester) as a fix for what many in the PA solar industry view as an SREC market with prices trading at unsustainable levels. The bill’s core proposal is to move forward the Pennsylvania SREC requirement by three years – effectively accelerating SREC requirements in an attempt to stabilize the market. A hearing was held in the Pennsylvania House Consumer Affairs Committee in January 2012 and 108 (enough to pass the bill in the House) committed to vote for the bill if it passed out of committee. Lobbyists were also able to garner a substantial amount of support in the Senate.

Why hasn’t the bill passed yet?

Despite the January hearing on HB 1580 the bill was never put up for vote in the House Consumer Affairs Committee. The decision to do so is the responsibility of Committee Chair Rep. Bob Godshall (R-Montgomery) who has taken counsel from stakeholders both for and against the bill.  The coalition of groups supporting HB 1580 emphasize in their communication with stakeholders that HB 1580 is meant to provide support for jobs created by the nascent Pennsylvania solar industry at little to no additional cost to ratepayers. However, the Pennsylvania Chamber of Commerce along along with other groups representing natural gas and other interests are opposed to the bill.  Furthermore, strong pressure for and against the bill has made it a tough topic to address amid the latest election cycle.

Another push

Pennsylvania stakeholders that support HB 1580 have the option to lobby key members of the Pennsylvania legislator to get the bill put up for vote. HB 1580 advocates are encouraged to call the following three members of the PA House leadership.

Trade-offs Begin – NJ S1925 Update

Posted May 18th, 2012 by SRECTrade.

For a PDF copy of this post click here.

Yesterday, the Senate Environment and Energy Committee passed S1925 out of committee. Coming out of the session, the bill was revised to increase the Solar Renewable Portfolio (RPS) % requirements and decrease the Solar Alternative Compliance (SACP) schedule. Next, the bill will move on to a second reading in the Senate. The charts below demonstrate the difference between the original and revised versions of S1925.

How Does This Impact New Jersey’s Future SREC Requirements?

In our last research note on S1925, we took a look at a summary of the bill and provided analysis on how it could impact the New Jersey SREC market. Given the revision of the Solar RPS % requirements, below is an update to the original analysis.

The table below shows the SREC quantities required under the current RPS versus the estimates required under the revised version of S1925. Although S1925 increases the RPS requirements in the near term, the % requirements estimate a decrease vs. the current requirements beginning in 2024.

While the revised version of S1925 takes the steps needed to prop up the NJ SREC market, a closer look suggests that even if this bill comes to fruition the market could continue to be oversupplied. The table below shows the current RPS and revised S1925 requirements through 2017. Both scenarios demonstrate what the markets look like given estimates of installed capacity through April 30, 2012, and assume that excess, eligible SRECs from prior periods are used to meet the compliance obligations in the current period. Under the current RPS requirements, assuming no new build, the market is oversupplied through energy year 2016. Applying these same figures to the estimated SRECs required if the revised version of S1925 is implemented, the market is short approximately 411,800 SRECs in 2014 (the equivalent of approximately 343.2 MW operational all year long).

Although the requirements under the current installed capacity and proposed changes under the revised version of S1925 put the market at under supply with no new build, the likelihood of that is minimal. Over the last twelve months (LTM), the average MW installed per month has been 36.0 MW. That figure over the last 6 months has reached 44.9 MW/month. Given the recent historic build rates, we have analyzed 3 different scenarios in which the following cases are assumed:

1) Case 1 – shows half of the LTM average MW added per month throughout the course of the annual forecast periods;

2) Case 2 – shows the LTM average MW added per month remains the same throughout the annual forecast periods;

3) Case 3 – shows 1.5x the LTM average MW added per month throughout the annual forecast periods.

Note, for the purpose of obtaining an ending balance of MW capacity as of May 31, 2012, the table below assumes another 36.0 MW is added in the month of May 2012.

Under the revised version of S1925, the market is less oversupplied or under supplied depending on the case displayed above. One of the main differences between the table above an our original estimates is that if installations slow down to half of the LTM monthly average rate, Case 1, the market could be under supplied as early as 2015. It is important to note that each case assumes all excess, eligible SRECs from the prior period are utilized to meet the current year RPS requirements.

As demonstrated in the scenario analysis, the market would need to substantially slow down current monthly build rates to allow supply to come in line with demand in the future RPS compliance periods. The revised version of S1925 attempts to lessen the impact of oversupply, but even under the updated table above, all three cases show oversupply through at least 2014. Additionally, the trade off of an increased Solar RPS % came at the cost of reducing the SACP. Thus, although the NJ solar industry can continue to build projects at a reduced rate, new installs will have to be underwritten with the understanding that less value will be derived from SRECs.

Note: Percentage based SREC requirements have been forecast based on EIA Report updated 11/15/11 “By End-Use Sector, by State, by Provider”. Projected SRECs required utilizes the most recent EIA electricity data applying an average 1.5% growth rate per forecast year. The state’s RPS Solar requirement is then multiplied by forecast total electricity sales to arrive at projected SRECs required. Projected capacity required is based on a factor of 1,200 MWh per MW in New Jersey.

Proposed New Jersey Solar Bill May Not Solve SREC Woes

Posted May 16th, 2012 by SRECTrade.

For a PDF copy of this post click here.

Introduction

Senators Bob Smith and Stephen Sweeny recently introduced New Jersey Senate Bill 1925. The bill proposes to amend New Jersey’s current Solar Renewable Portfolio Standard (RPS) requirements in attempt to help stabilize the oversupplied SREC market. The bill is currently in draft form and is scheduled to be heard by the New Jersey Environment and Energy Committee on Thursday, May 17, 2012.

Based on the information presented below, the proposed version of S1925, while increasing the near term Solar RPS requirements, will likely still leave the market oversupplied. This note summarizes the key points in the draft legislation and quantifies the near term and long term impacts it would have on the SREC market if passed into law.

Summary of S1925

Senate Bill 1925 proposes a few substantial changes that would influence New Jersey’s RPS requirements beginning in the 2014 compliance year (June 1, 2013 – May 31, 2014). The chart below demonstrates the change from a fixed SREC requirement under the current RPS to a % based Solar requirement under S1925. The Solar RPS requirements would change beginning in the 2014 compliance year, with a requirement of 1.832% increasing to 3.730% by the 2028 energy year.

Additionally, the table below shows the SREC quantities required under the current RPS versus the estimates required under S1925. While S1925 increases the RPS requirements in the near term, the % requirements estimate a decrease vs. the current requirements beginning in 2023.

Beyond the proposed changes in SREC requirements, S1925 would implement a new fixed Solar Alternative Compliance Payment (SACP) schedule. The schedule reduces the SACP beginning in 2014 to $350/SREC declining to $252/SREC in 2028. The implementation of this schedule will cap SRECs at a price of $350 in 2014 and decrease in future periods. The table below demonstrates the proposed schedule as compared to the current RPS requirements.

In addition to S1925’s proposed SREC and SACP changes, the bill also addresses a few other areas:

1) An SREC’s useful life would extend from 3 to 5 years; giving it eligibility in the year in which it is issued and the following four energy years.

2) During 2014, 2015, and 2016, approved non-net metered grid supply projects cannot exceed more than 100 MW in total aggregated capacity each year. Grid supply projects located on brownfields are not limited under this stipulation. After 2016, the approval of grid supply projects would be subject to review by the Board of Public Utilities (BPU).

3) Solar RPS requirements would automatically increase by 20% for the remainder of the schedule in the event that the following two conditions are met: 1) the number of SRECs generated meets or exceeds the requirement for three consecutive reporting years, beginning with energy year 2014 and 2) the price for SRECs purchased by entities with renewable energy portfolio standards obligations in each of the same three consecutive reporting years is less than the current SREC price in the year prior to the three consecutive reporting years (i.e. if the price in 2014, 2015, and 2016 is less than the 2013 price and the number of SRECs exceeds the requirement in each of these years, the 20% increase in the RPS will be triggered).

What Does This Mean for the NJ SREC Market?

While S1925 takes the steps needed to prop up the NJ SREC market, a closer look at the numbers suggest that even if this bill comes to fruition the market could continue to be oversupplied. The table below shows the current and proposed S1925 RPS requirements through 2017. Both scenarios demonstrate what the markets look like given estimates of installed capacity through April 30, 2012, and assume that excess, eligible SRECs from prior periods are used to meet the compliance obligations in the current period. Under the current RPS requirements, assuming no new build, the market is oversupplied through energy year 2016. Applying these same figures to the estimated SRECs required if S1925 is implemented, the market is short approximately 118,500 SRECs in 2014 (the equivalent of approximately 98.8 MW operational all year long).

Although the requirements under the current installed capacity and proposed changes under S1925 put the market at under supply with no new build, the likelihood of that is minimal. Over the last twelve months (LTM), the average MW installed per month has been 36.0 MW. That figure over the last 6 months has reached 44.9 MW/month. Given the recent historic build rates, we have analyzed 3 different scenarios in which the following cases are assumed:

1) Case 1 – shows half of the LTM average MW added per month throughout the course of the annual forecast periods;

2) Case 2 – shows the LTM average MW added per month remains the same throughout the annual forecast periods;

3) Case 3 – shows 1.5x the LTM average MW added per month throughout the annual forecast periods.

Note, for the purpose of obtaining an ending balance of MW capacity as of May 31, 2012, the table below assumes another 36.0 MW is added in the month of May 2012.

In each of the 3 cases presented above, the market ends up in oversupply through at least 2016. It is important to note that each case assumes all excess, eligible SRECs from the prior period are utilized to meet the current year RPS requirements.

As demonstrated in the scenario analysis, the market would need to substantially slow down current monthly build rates to allow supply to come in line with demand in the future RPS compliance periods. It‘s unlikely that build rates will decline fast enough to protect from future oversupply. This bill does not allow for an increase in build rates (it requires a decrease) and cannot be used as a justification for an increase in PV installation growth.

Reaching the install rates shown in Case 1 (approx. 18 MW/month) should be within reach despite the restrictions put on grid supply projects. Additionally, the potential introduction of new EDC SREC programs, as well as historic build rates in the residential and commercial sectors, will also contribute to meeting the levels outlined in Case 1. Clearly, SREC pricing and availability of forward contracts to support new project development will impact future build rates, but even in markets with an oversupply of solar (i.e. PA), projects continue to be built without much regard for the current SREC environment.

How Does this Impact the 2012 and 2013 energy years?

Under the current draft of S1925, the RPS requirements would be unaffected in 2012 and 2013. The 2012 generation period will come to a close at the end of May 2012. Compliance buyers will have until approximately the end of September to wrap up their purchases before finalizing RPS reports with the BPU. As it currently stands, we estimate the NJ2012 market to see an excess of approximately 180,000 SRECs. Recent over the counter trading has increased to levels between $125 and $135/SREC, up from the last SRECTrade auction clearing price at just above $115/SREC.

The Electric Distribution Companies (EDCs), or regulated utilities, in NJ will be holding an auction on Thursday, May 17, 2012. Recent announcements show that as many as 33,000 NJ2012 SRECs will be available for sale during this auction. Given these volumes, 2012 demand may be reduced after this auction.

In addition to the 2012 energy year, the 2013 compliance period is fundamentally oversupplied. Current estimates show the 2013 period will see an excess of approximately 496,000 SRECs. This estimate takes into consideration the excess SRECs from 2012 and installed capacity estimates through April 2012. The 2013 forward market has recently traded above the 2012 vintage, but given the fundamental oversupply it is likely pricing will trend downward throughout the 2013 compliance period beginning June 1, 2012 (note the first 2013 vintage SRECs will not be issued in GATS and available for delivery until the end of July 2012).

SRECTrade will continue to keep a close eye on the S1925 legislative process as it makes its way through the Senate Environment and Energy Committee and the remaining requirements needed before it can be signed into law.

Note: Percentage based SREC requirements have been forecast based on EIA Report updated 11/15/11 “By End-Use Sector, by State, by Provider”. Projected SRECs required utilizes the most recent EIA electricity data applying an average 1.5% growth rate per forecast year. The state’s RPS Solar requirement is then multiplied by forecast total electricity sales to arrive at projected SRECs required. Projected capacity required is based on a factor of 1,200 MWh per MW in New Jersey.

Maryland Update – Senate Passes SB791

Posted April 4th, 2012 by SRECTrade.

Today, the Maryland Senate voted 37-9 in favor of Senate Bill 791. We have been following this piece of legislation closely and have provided estimates and analysis around its impact on the Maryland Solar REC market.

Overall, the legislation pulls forward the Solar RPS requirements, reaching the existing 2022 Solar % requirements in 2020. The chart below demonstrates the existing requirements vs. the proposed requirements under the new legislation.

MD Solar RPS Current vs. HB1187

The next step for the bill is to move on to the Governor’s office to be signed into law.  Maryland stakeholders expect the legislation to be well received by the Governor who will likely sign the bill in May.

We’ll continue to provide updates as the bill is finalized and signed into law. Before then we should point out this bill was successfully promoted in part due to the efforts of the Maryland-DC-Virginia Solar Energy Industries Association (MDV-SEIA) and strong grassroots support from Maryland stakeholders at large.

Update – Maryland Proposes New Solar Legislation

Posted April 2nd, 2012 by SRECTrade.

Since our last update on legislation to adjust the Solar RPS requirements in Maryland, there has been some movement in both the House and the Senate.

After HB1187 passed out of the House Economic Matters Committee, the bill was heard on the floor of the House and passed unanimously 131-0. Earlier last week, the Senate version of the bill, SB791, was voted down in the Senate Finance Committee, 4-7. The bill was then reconsidered by the committee the other day with the original vote being overturned, 8-2 (with one abstention).

The next stage for SB791 is to bring it up for vote on the floor of the Senate. Stakeholders expect this will take place Monday or Wednesday of this week. Some have expressed that the bill may be met with some resistance from the Senate, but it is expected that should it pass out of the Senate it will be well received by the Governor.

If you have an interest in voicing your thoughts on this piece of legislation, feel free to visit this link to find your appropriate representative. We’ll continue to provide updates through our blog as the bill makes its way through the process.

Pennsylvania Solar Bill Goes to Committee

Posted January 17th, 2012 by SRECTrade.

On Wednesday, 1/11/12, Pennsylvania House Bill (HB) 1580 sponsored by Rep. Chris Ross (R-Chester) was presented to the House Consumer Affairs Committee for debate.  HB 1580 is a proposal to move forward the Pennsylvania SREC requirement to the current compliance requirement for 2015 without changing the overall number of SRECs required after 2015. This would alleviate the over-supply of SRECs and increase the value of Pennsylvania SRECs.  While the hearing was a critical first step for HB 1580, followers of the Pennsylvania solar industry will have to wait on the Consumer Affairs Committee’s vote before the fate of the bill is known. Should the bill make it out of committee it will also need to pass the House and Senate where both the House and Senate have voiced initial majority support for bill.

During the hearing solar industry representatives and solar consumers testified in support of the bill while utility groups and the Pennsylvania Chamber of Business spoke against it. The PA Environment Digest put together a detailed account of the testimonies. Generally those in support of the bill argue: 1) that the bill is essential for maintaining highly skilled solar jobs in Pennsylvania; 2) doesn’t increase the overall requirement for SRECs; 3)merely accelerates the requirement and 4) brings Pennsylvania’s SREC market more in line with the design of other SREC markets by closing the market to out-of-state sited systems (currently PA accepts SRECs from anywhere in the PJM region i.e most states in the mid-Atlantic and some states in the Midwest). Utility companies that testified against the bill argue that it would place an undue burden on rate payers by forcing utilities to charge more for the electricity that they supply. According to the PA Environment Digest article, there was some disagreement over the actual cost of the bill to rate payers, but on the high side utilities estimate that it would be an increase of $120 million over four years to four million Pennsylvania rate payers, which equates to an increase of about $3.33 per year to each rate payer.

SRECTrade will continue to closely monitor the development of HB 1580. Stay tuned to our blog for updates.