Posts Tagged ‘Pennsylvania’

PA PUC Enters Final Implementation Order of Act 40

Posted May 10th, 2018 by SRECTrade.

On Thursday, May 3rd, the Pennsylvania Public Utilities Commission (PUC) entered its Final Implementation Order of Act 40 of 2017, clarifying some questions that remained from its adoption of the Final Implementation Order. Notably, the entry confirmed that PA-certified but out-of-state facilities would not be grandfathered with solar renewable energy credit (SREC) eligibility (i.e. Tier I solar), since the PUC found that grandfathering these facilities would result in minimal improvement for state SREC prices and fail to effectuate the intentions of the PA General Assembly.

The entry also clarified that PA SRECs associated with energy generated after October 30, 2017 would be re-certified to non-solar RECs (i.e. Tier I non-solar). The PA REC Program Administrator and PJM GATS have already worked together to modify the Tier I certification numbers attributed to all out-of-state facilities and SRECs that no longer qualify for Tier I solar eligibility. This means that SRECs with a Month of Generation of November 2017 and later have now been re-certified as Tier I non-solar RECs.

Some facilities that were re-certified with Tier I non-solar eligibility will be permitted to temporarily maintain SREC certification if under an SREC contract with an electric distribution company (EDC) or electric generation supplier (EGS) serving PA customers. EDCs and EGSs seeking to qualify contracted RECs as Tier I solar-eligible under the Final Implementation Order’s ruling must file a petition within 60 days of the entry date of the Order (May 3rd). Please note that such facilities will only be permitted to maintain certification until the expiration of the SREC contract.

Moving forward, it appears that the PA REC Program Administrator will be responsible for working with PJM GATS to re-certify SREC-contracted facilities for Tier I non-solar REC generation once their contract term expires.

Additionally, the entry clarified that:

  • Solar facilities interconnected in PJM service territory are permitted to continue generating RECs eligible to be used toward Tier I non-solar requirements in the AEPS.
  • Out-of-state grid-supply solar facilities must be serving end-use electricity load in PA to continue to generate energy and SRECs eligible for compliance under the Tier I solar requirement. Specifically, solar facilities must meet one of the following criteria:
    • Physical connection to a PA EDC customer’s internal electrical system
    • Physical interconnection to an EDC’s distribution system
    • Physical connection to a PA electric cooperative’s or municipal electric system’s distribution network
    • Physical connection to any PA-located transmission system, including utility-scale solar facilities that are within a PA EDC’s service territory and operating under PJM wholesale generator rules
  • SRECs generated by out-of-state facilities prior to October 30, 2017 will maintain their Tier I solar certification

PA PUC Adopts Final Implementation Order of Act 40 – Impacts Out-of-State PA-Certified Solar Projects

Posted April 19th, 2018 by SRECTrade.

On Thursday, April 19th, the Pennsylvania Public Utilities Commission (PUC) adopted its Final Implementation Order of Act 40 of 2017. The Order amends the qualifications to certify Tier I solar photovoltaic facilities under Pennsylvania’s Alternative Energy Portfolio Standards (AEPS) Act. As summarized in our previous blog post, ambiguous language in Section 2804(2)(i) and Section 2804(2)(ii) of Act 40 made it unclear whether certified but out-of-state facilities would retain their certifications under the AEPS. The Order clarified the PUC’s interpretations of Section 2804(2)(i) and Section 2804(2)(ii) which are as follows:

  • Section 2804(2)(i) – “[a] certification originating within the geographical boundaries of this Commonwealth…” shall mean a facility located within PA having received an AEPS Tier I solar photovoltaic certification.
  • Section 2804(2)(ii) – shall only permit out-of-state facilities that are 1) already certified as AEPS Tier I Solar Photovoltaic and 2) entered into an SREC contract with a PA electric distribution company (EDC) or electric generation supplier (EGS) serving PA customers to maintain certification until the expiration of the contract.

Solar facilities that meet the two Section 2804(2)(ii) criteria listed above are limited to maintaining certification only for the applicable amount of Solar Renewable Energy Credits (SRECs) contractually committed to an EDC or EGS. EDCs and EGSs seeking to qualify SRECs under this interpretation must file a Petition with 60 days of the entry date of the Order.

In addition, the Order clarified that SRECs generated by certified but out-of-state facilities prior to October 30, 2017 will retain their Tier I solar qualification for their standard banking lifetime (current reporting year and following two). The Order did not clarify whether SRECs generated by such facilities after October 30, 2017 will also be able to retain their Tier I solar qualification.

At this time, it is unclear how implementation of these interpretations will be administered. SRECTrade will continue to monitor the proceedings and provide updates as they become available.

OH and PA SREC SREC Market Webinar: Tuesday, 4/8 @ 2 pm ET

Posted March 27th, 2014 by SRECTrade.

SRECTrade will host a webinar covering the latest pricing and supply numbers for the OH and PA SREC markets.

The webinar is open to the public and will be held on Wednesday, 4/8/14, at 2 pm ET.

Click here to register

OH and PA SREC market update

Why are Pennsylvania SREC prices so low?

Posted February 16th, 2012 by SRECTrade.

SRECTrade has printed auction prices for Pennsylvania ranging from a high of $310 in June 2010 and a low of $20 for SRECs created in the same energy year. The drop in Pennsylvania SREC prices is due to a severe over-supply of SRECs above the amount of SRECs that buyers (electricity producers) need to acquire each year, but how did the market become over-supplied and is anything being done to address the over-supply?

Background

The Pennsylvania SREC market was created as a state-level, long-term incentive for homeowners and businesses to go solar, but around the same time that the SREC market was created, other, more generous solar rebate programs like the Pennsylvania Sunshine Program were created that caused a short-term boom in solar installations. In addition to this, the Pennsylvania SREC market is one of two markets (OH is the other) that accept SRECs from out-of-state sited solar systems, including from states that don’t have their own SREC markets. This means that Pennsylvanians are effectively subsidizing solar in other states and ensuring that Pennsylvania SREC prices remain low.

The Proposed Fix

The Pennsylvania SREC market was created by the state legislature and amendments to the market must go through the legislature first. In the spring of 2011, Rep. Chris Ross (R-Chester) proposed House Bill (HB)-1580 to address some of the key factors behind low Pennsylvania prices. The crux of HB 1580 is a proposal to move up the SREC requirement by three years. This would mean that if the bill passed, Pennsylvania SREC requirements would increase beginning in 2013. A detailed schedule of the proposed increase can be found in the bill.

We’ve followed the progress of HB 1580 over the last year and periodically posted updates to our blog.  Most recently the bill went before the House Consumer Affairs Committee on January 11, 2012 where it met resistance from Committee Chair Rep. Bob Godshall (R-Montgomery) and various entrenched groups representing the Pennsylvania electricity industry. Since the January hearing Rep. Chris Ross has worked hard to develop compromise amedments to HB-1580 that might help the bill survive a tough Committee vote. If the bill makes it out of Committee it has 110 co-sponsors in the House and substantial Senate support in a companion bill.

According to PennFuture, a Pennsylvania environmental and renewable energy advocacy group, Ross’ proposed the following compromises:

  • Capping the Alternative Compliance Payment (ACP) for solar at $325, with a 2% annual decline
  • Offsetting early-year increases in the solar requirement with decreases in later years and extending the SREC program through 2026
  • Allowing solar hot water (SHW) systems to qualify for SREC sales
  • Making slight adjustments to the language of the in-state requirement, aimed at preventing net-metered systems from inadvertently being disqualified
  • Ensuring that utilities cannot procure any AEPS resource above the ACP price

What Can You Do?

Pennsylvania solar advocates are hoping that they can convince the House Consumer Affairs Committee to vote on HB 1580 when the legislature reconvenes in mid-March. If you are a Pennsylvania resident, please feel free to contact House Majority Leader Turzai at 717-772-9943 to express your support for seeing the bill go up for vote.

Hearing on Pennsylvania SREC Bill (HB 1580) delayed again

Posted December 7th, 2011 by SRECTrade.

A critical Pennsylvania House Consumer Affairs Committee hearing on the Pennsylvania Solar Jobs Bill (HB 1580) scheduled for Thursday, December 8th was delayed again, according to a news flier sent out by the Pennsylvania advocacy group PennFuture. This is the 2nd time that the hearing has been delayed in as many weeks. According to the PennFuture flier, the bill hearing was delayed due to a death in Committee Chair Rep. Godshall’s family. No reschedule date has been announced yet.

PSEIA: HB1580 creates thousands of jobs for less than half a penny a day

Posted November 23rd, 2011 by SRECTrade.

On November 16th, 2011, the Pennsylvania Solar Energy Industries Association (PASEIA) released its Ratepayer Cost Analysis regarding PA House Bill #1580. HB1580 was introduced on October 3rd, 2011 by Rep. Chris Ross, and includes 109 co-sponsors as of November 10th, 2011.

The Bill was introduced to address the recent collapse of the PA SREC market by accelerating the solar share requirement from 2012 through 2015. While the solar share requirements from 2012 through 2015 have been accelerated, the solar share requirements in 2016 through 2018 remains the same as SREC prices are expected to have stabilized by then regardless of the present situation. HB1580 will also close the solar market in Pennsylvania to out-of-state systems, thus limiting the supply of SRECs available which will drive up their value. While undoubtedly a blessing for the solar industry within Pennsylvania, some concerns have been raised regarding the impact this program will have on ratepayers. The Ratepayer Cost Analysis aims to address these issues.

Here is the breakdown of HB1580, using figures derived from the Cost Impact Report. The introduction of HB1580 imposes an additional $113,315,417 distributed amongst all residential and commercial power users in Pennsylvania.

Current Scenario

Reporting Year Solar Share SRECs SREC Price* Cost
2012 – 2013 0.0510% 75,189 $50 $3,759,453
2013 – 2014 0.0840% 123,012 $50 $6,250,621
2014 – 2015 0.1440% 216,338 $50 $10,816,879
2015 – 2016 0.2500% 379,150 $70 $26,540,513
2016 – 2017 0.2933% 449,047 $80 $35,923,723
2017 – 2018 0.3400% 525,500 $85 $44,667,471
Total 1,770,235 $127,958,661

Proposed Scenario (HB1850)

Reporting Year Solar Share SRECs SREC Price* Cost Increment
2012 – 2013 0.1500% 221,144 $190 $42,017,420 $38,257,967
2013 – 2014 0.1700% 253,001 $150 $37,950,200 $31,699,579
2014 – 2015 0.2040% 306,478 $125 $38,309,780 $27,492,901
2015 – 2016 0.2500% 379,150 $100 $37,915,019 $11,374,506
2016 – 2017 0.2933% 449,047 $90 $40,414,188 $4,490,465
2017 – 2018 0.3400% 525,500 $85 $44,667,471 $0
Total 2,134,320 $241,274,078 $113,315,417

* SREC price is based on aggregator feedback, as well as average weighted PA SREC prices in GATS

The cost imposed on each ratepayer is than calculated based on an estimated use of 10,716kWh/yr for residential and 150,000kWh/yr for commercial usage.

Reporting Year Estimated Elect Sales Estimated Increased Cost

Cost Increase per kWh

Estimated Increased Residential Cost Estimated Increased Commercial Cost
Annual Monthly Annual Monthly
2013 147,429,544 $38,257,967 $0.0002595 $2.78 $0.23 $38.93 $3.24
2014 148,824,315 $31,699,579 $0.0002130 $2.28 $0.19 $31.95 $2.66
2015 150,234,430 $27,492,901 $0.0001830 $1.96 $0.16 $27.45 $2.29
2016 151,660,076 $11,374,506 $0.0000750 $0.80 $0.07 $11.25 $0.94
2017 153,101,443 $4,490,465 $0.0000293 $0.31 $0.03 $4.40 $0.37
2018 154,558,725 $0 $0
Total $113,315,417 $8.14 $0.68 $113.97 $9.50
Average $0.0001520 $1.63 $0.14 $22.79 $1.90

As the table shows, the residential bill on average increases by less than 14 cents over five years and under $2 for commercial customers with an assumed annual electric usage of 150,000kWh/yr. This amounts to less than half a penny a day for residential owners. In addition, these are pre-tax costs, so for-profit commercial and industrial customers will pay less than these estimates based on their effective tax rates..

For more information, please contact:
Ron Celentano
PASEIA – President
CelentanoR@aol.com

Pennsylvania Legislative Update: HB 1580 Still in Committee and In Need of Support

Posted October 28th, 2011 by SRECTrade.

Over 90 members of the Pennsylvania solar industry lobbied Pennsylvania legislators on Monday, 10/28/11 to voice their support HB 1580 an SREC bill. The effort was part of an official “Pennsylvania Solar Advocacy Day” event put on by PennFuture, Solar Alliance, Vote Solar, PASEIA and others. By the end of the day more than 108 members of the Pennsylvania House (of a required 100) had offered to sponsor the legislation should it make it out of committee.

House Bill 1580 (sponsored by Rep. Chris Ross, R-Chester) proposes to move the total requirement of SRECs forward by three years to increase the number of SRECs Load Serving Entities (utility-scale “dirty” electricity producers) must purchase. The rapid implementation of Pennsylvania SREC eligible facilities over the last year has led to an SREC over-supply of more than double the amount of SRECs needed by utility-scale electricity producers. This over-supply is responsible for low SREC pricing in Pennsylvania.

SREC markets are driven by the fundamentals of supply and demand. However in Pennsylvania demand (the amount of SRECs required for a given year) is significantly lower than the number of SRECs available. The Pennsylvania SREC market is designed in such a way that every year there is a set goal for amount of power that comes from renewable energy sources and any adjustment to the yearly goal requires legislative action.

In order for the bill to move forward it needs the support of Rep. Bob Godshall, Chairman of the House Consumer Affairs Committee for Committee vote. PennFuture has asked the Pennsylvania solar community to write Rep. Godshall to show their support of the bill. However, even if the bill gets out of Committee in its current form it still needs to pass the House and Senate.  With 108 state Representatives co-signing the bill it is expected to pass the House, but it’s unclear how it will fair if it reaches the Senate.

Stay tuned for more HB 1580 Updates.

Pennsylvania Solar Advocacy Day (Monday, Oct. 24th)

Posted September 27th, 2011 by SRECTrade.

On Monday, October 24th PennFuture, Vote Solar, the Solar Alliance, and SUNWPA will hold a Solar Advocacy Day and Evening Reception at the Capitol building in Harrisburg. If you are part of Pennsylvania solar community this is an opportunity to educate policymakers and the media about solar in your state. The main focus of the advocacy day will be the support of the Solar Jobs Bill, which we’ve written a few blog postings about.

Here are the websites for the participating groups:

Vote Solar: national grassroots solar advocacy group
PennFuture: Pennsylvania environmental advocacy group
Solar Alliance: state-focused solar industry group
SUNWPA (Solar Unified Network of Western Pennsylvania): sub-group of PennFuture without a formal website

Click here to take action. Use the link to let your local PA state representative know that you support solar in PA.

If you have an advocacy event that you’d like SRECTrade to know about please email installers@srectrade.com

PA’s Latest Attempt to Increase Solar Requirements – HB 1128

Posted November 12th, 2010 by SRECTrade.

At the end of September, Pennsylvania lawmakers introduced HB 1128. The main focus of the bill is to amend the requirements under PA’s Alternative Energy Portfolio Standards (AEPS) by increasing the amount of renewable energy to come from Tier I alternative energy sources and Solar Photovoltaic technologies. In addition to increasing the requirements, HB 1128 attempts to amend the program by introducing a fixed alternative compliance payment (ACP) for the Solar PV portion of the AEPS. Currently, the ACP under the PA solar carve-out is derived based on 200% of the average SREC price paid by buyers during the reporting year. The ACP in RY2008 and RY2009 was $528.17 and $550.15 per MWh, respectively. The table below demonstrates the the key changes to the solar requirements, attempting to increase the total requirement 3 times the current level by the 2022 energy year.

HB1128 Table_Crop

Positive Impacts of HB 1128
The increase in PV capacity would help support the growing solar economy in Pennsylvania and provide more room under the current requirements for more solar to come to market. The current PA market has over 2,900 solar projects registered and eligible for the AEPS program. The total nameplate capacity of these projects is equal to 51.8 MW. Of these 2,900 projects only four projects are greater than 1 MW. In addition to being eligible for the PA SREC market, many of these facilities could also be registered in other states such as Ohio and Washington D.C.

The current capacity of solar projects eligible for the PA market is greater than the requirements for the current energy year. The implementation of HB 1128 would allow for the solar market to continue to grow and support the development of projects of all sizes, from small rooftop residential to larger multi-MW utility scale solar systems. Pennsylvania’s inability to implement some sort of amendment to increase the solar RPS requirements could result in a migration of PA’s solar industry to other surrounding states such as New Jersey, Maryland, and Delaware which have all recently increased the requirements of their solar RPS programs and maintain fixed alternative compliance payment schedules. It has been estimated that the increase in the AEPS program could create at least 14,000 jobs over the next ten years. A stronger solar policy in PA will not only help create new, clean energy focused jobs, but will help move the state towards a more energy independent future.

Compared to HB 2405, the treatment of out-of-state facilities is not addressed in HB 1128. Though the future acceptance of out-of-state facilities can be left up to the lawmakers to debate, the major problem with HB 2405 was that it excluded existing facilities from neighboring states that have been financed based on being accepted into the SREC program in Pennsylvania. This disregard for the existing out-of-state facilities is unacceptable. Fortunately, HB 1128 does not address this issue. Any future Bill to address this topic should at the very least grandfather in any previously approved facilities.

Negative Impact of HB 1128
Despite the need for an increased requirement, PA HB 1128 may not be the answer because of the low ACPs that are included in the Bill.  It could depress SREC market pricing to levels that could be prohibitive to the economics of solar today.  There are few financeable projects at SREC values below $200, especially when there is limited access to long-term contracts. Compared to other state markets, PA would have the lowest ACP and be heading in the opposite direction of states like Delaware, Maryland and New Jersey that have increased the fines to encourage growth and discourage electricity suppliers from paying the ACP.

Pennsylvania’s Current ACP
Meanwhile, the current ACP in Pennsylvania has not been implemented the way it was intended, which could have an impact on the market in the long run.  The way the law was written, the intent was to fine electricity suppliers 200% of the average SREC purchase price in the PJM region. i.e. keeping them in check with neighboring state markets.  Most likely because this was somewhat vague and difficult to calculate, the ACP was interpreted differently by the organizations implementing the program. Instead of being fined based on neighboring state markets, the interpretation of the ACP was that since Pennsylvania accepted SRECs from throughout the PJM region, it was a fair indication of the average price in the region. Therefore, Pennsylvania uses an ACP of 200% of the average price paid for compliance in Pennsylvania. Instead of keeping buyers in the PA market in check with other states, the ACP in Pennsylvania keeps buyers in check with themselves. The goal for buyers in Pennsylvania is to keep the average price down, so that the fines will remain low in non-compliance years. In reality, the price paid will ultimately have to be just enough to get a project done, though the market would be far more stable if the ACP were implemented as it was originally intended.

Click here for a link to the HB 1128 summary.

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Pennsylvania SREC Market in 2010

Posted February 19th, 2010 by SRECTrade.

Despite a robust RPS and the threat of non-compliance fines above $550, the Pennsylvania SREC market has been slow to develop. We take a quick look at some of the factors that influence this market and hopefully provide some insight as to why the Pennsylvania SREC demand has been low.

Demand Issues: For starters, the PA RPS is expected to ramp up as described on our Pennsylvania Page. Based on current electricity sales into Pennsylvania, we project the demand for SRECs to be as follows:

Pennsylvania SREC ProjectionsAccording to this projection, approximately 20,000 SRECs need to be purchased in Pennsylvania for generation through May 31, 2010. However, the reality is a bit more complex. Electricity markets are composed of three types of companies: electricity generators who supply the power, electricity transmitters responsible for transmission and electricity distributors responsible for the delivery of the retail electricity. It is important to know that although the distribution companies (EDCs) or retail utilities are most commonly associated with state RPS goals, it is actually the numerous electricity suppliers who are responsible for purchasing the SRECs to meet the RPS. The Pennsylvania electricity market is comprised of 11 Electricity Distribution Companies (EDCs).  Behind each EDC are the many suppliers providing power to them.  When the PA RPS was passed, the suppliers for several EDCs were exempted for the first few years. According to the DSIRE website, these EDCs were exempted because they were under rate freezes or still recovering from costs associated with restructuring. In all, 5 of the 11 EDCs are exempt. The exemption ended this January of 2010 for one of the EDCs and the exemption for the other 4 will expire in January of 2011.  More significantly, these EDCs represent over 85% of the total electricity market exempt through January of 2010 and 70% exempt through January of 2011!  With that said, this changes the outlook for SREC demand in Pennsylvania substantially in 2010 and 2011:

Pennsylvania EDC SREC BreakdownAs a result, the actual demand for PA SRECs in the 2009-10 Energy Year drops from nearly 20,000 SRECs to under 5,000 SRECs – 25% of what was initially projected. In 2010-11, the demand drops from an initial projection of 33,000 SRECs down to 21,000 SRECs – about 60% of initial projections!

Procurement Issues: In addition to a decreased demand in the early years of the PA market, the state also has some constraints in place that have created challenges for buyers and sellers to connect in this market. For the first time in history, home and business owners are entering electricity markets as generators. These markets are geared towards large corporations that produce significant amounts of power, and as a result, the approach many companies have taken to procuring SRECs is geared towards large companies (as an aside, this is why GATS is such a cumbersome platform for solar owners). In addition, since most of these companies are heavily regulated, protections are put in place to ensure a competitive process. Unfortunately, these protections are also geared towards large companies.  The end result is that the Pennsylvania Public Utilities Commission (PUC) requires buyers to use a competitive RFP process.

Well, the problem is that most solar owners don’t even know what an RFP is, let alone have the requirements in place to be eligible. This explains why most RFPs for SRECs are severely under-prescribed and why in late 2009, PPL successfully petitioned the PUC to lessen the credit requirements necessary to bid in their RFP. Instead of being required to have a credit rating and listing with an accredited credit agency, you now only needed to put up a letter of credit to bid on the opportunity to sell SRECs in minimum bundles of 500!

Fortunately, it seems that the PUC continues to re-evaluate this process and the constraints they have placed on the suppliers.  Most recently, they have proposed a change to their policy to allow suppliers to enter into a restricted volume of bi-lateral contracts that are also restricted in value by the average value of SRECs procured in the adjacent RFPs. You can read the proposal and we encourage you to submit your comments. While this is a step forward, we still believe that this will likely incentivize the same companies bidding on RFPs to just enter into the bi-lateral contracts, squeezing out the rest of the market.  We setup our auction to ensure a competitive process that is accessible to all market participants and hope that future iterations of PUC policy changes will better address the entire SREC market and allow more compliance buyers to enter into auctions like SRECTrade without having to jump through legal hoops in order to do so.

Conclusion: The Pennsylvania SREC market has an extremely promising future and all signs are pointing in the right direction. We believe that this is an iterative process. Looking back at the lead taken by New Jersey, their SREC program has been amended several times and it is now inspiring a prolific SREC market. Pennsylvania will continue to tweak its program until the market truly is more efficient and effective in promoting solar. Until then, we at SRECTrade are doing everything we can to bring buyers to the market, as well as set up other means for selling SRECs for our clients. The great news is that most facilities eligible in Pennsylvania are also likely to be eligible in DC and Ohio where in the short-term, SREC prices will be better. If you have any questions, as always, feel free to contact us.