Posts Tagged ‘Washington DC SREC changes’

Distributed Generation Amendment Act of 2011 Implemented

Posted September 27th, 2011 by SRECTrade.

The Council of the District of Columbia and the city’s Mayor signed into law the Distributed Generation Amendment Act of 2011. SRECTrade closely watched this legislation as it evolved over the last 7 months. Our most recent blog on the subject is here. The Act ultimately focuses on providing a sustainable SREC market for the residents of Washington DC while containing the potential cost to ratepayers. The amendment increases the RPS solar requirements and closes the District’s boarders from out-of-district sited systems. The affect on the market is demonstrated in our Capacity Update of systems eligible to create DC SRECs moving forward.

This week, the PJM tracking registry (PJM GATS) is undergoing the process of de-certifying systems that were once eligible under the previous Washington DC RPS law. As per the new legislation, all non-Washington DC sited systems that were approved after January 31, 2011 by the DC Public Service Commission are no longer eligible to sell SRECs in the DC market. This cutoff date is clearly displayed by a customer’s DC State Certification Number; any certification number beginning “DC-10…-SUN-I” was certified before January 31, 2011, while any certification number beginning “DC-11….-SUN-I” was certified after that date.

What does this mean for the market?

While this law is not likely to cause DC SREC prices to rebound immediately to the level that was seen in 2010 (due to the fact that buyers have likely accumulated extra SRECs throughout the early part of this year, along with any forward contracts that were in place before the law was implemented), this law is an important step to alleviating the oversupply that has depressed DC SREC prices.

What does this mean for facilities certified after January 31, 2011?

Any facility not located within Washington DC with the state certification number beginning “DC-11…” has had their certification number de-activated. The facility is no longer eligible to generate future SRECs in the DC market, and any SRECs they have already created have lost their eligibility for the DC SREC market.

- If your facility falls under this category, and is already eligible to sell SRECs in another state, you will not see any disruption in your account except that you are no longer eligible for the DC market.

- If your facility is eligible to be certified for another SREC market, but you were only certified in DC, you can apply for certification in another state market. Please see this chart for more information on your eligibility.

- If your facility was originally only eligible for DC (i.e. your system is located in WI, NY, NC(non-Dominion Power territory) or you had a Solar Thermal system not located within Washington DC), PJM GATS will be listing your facility as “inactive”. Any SRECs you have created will not be eligible for sale, and you will not create future SRECs unless another market opens that allows your facility to be certified. Currently, solar facilities in this scenario are only eligible in the NC SREC market – but due to extremely low pricing in the oversaturated NC market, this option is not very viable for solar owners.

SRECTrade will continue to post opportunities for cross-listing SRECs in other state markets.

Could change be coming to Washington DC’s SREC market?

Posted February 9th, 2011 by SRECTrade.

As you can see from our monthly update on the capacity registered in the SREC states, the DC market has requirements of no more than 8 MW of installations over the next two years. Today, there are over 27 MW currently generating SRECs that are eligible for the DC SREC market. Only 1.1 MW of the 27 MW are actually located within the District. This oversupply and weight towards foreign facilities is likely what prompted the potential legislative changes to the DC SREC market that we highlighted earlier.

This Bill is still in the early stages of the legislative process and it is unknown how long it would be before it is passed. However, it will take several months, at a minimum, before it would go into effect. At this point, it has been referred to the Committee on Public Services and Consumer Affairs, chaired by Councilmember Yvette Alexander who will establish the timing of hearings and markups of legislation.

After the hearing, it will likely go through an iterative process that will take several weeks before it is ready for a vote and another 2-4 weeks before a 2nd and final vote to enact the Bill before it is sent to the Mayor to sign. Once signed by the Mayor, the District must then send it to Congress for a lengthy review period.

The Bill seems to have enough support within the Council to have a good chance of being passed. Which then begs the question, how will they approach the grandfathering of out-of-state facilities that are already registered in DC. There are two important details here. First is the cutoff date. The initial date listed on the proposed Bill was January 31, 2011, however it is likely that if it takes several months to a year to enact the law, the actual cutoff date will be adjusted accordingly. The second detail is what defines “registered”. Would it mean any facility that was built prior to the cutoff date? Or is it any facility that has submitted an application to DC prior to the cutoff date? Or is it any facility that is approved prior to the cutoff date? The problem with the third approach is that the date an application is submitted is within the control of the solar owner, but the date that it is actually certified is not. We think it would be consistent with existing policies that DC would interpret “registered” as the date by which an application is submitted to DC.

SRECTrade will continue to follow the progress of this legislation. Any stakeholders interested in submitting testimony can do so by contacting the office of Councilmember Alexander.

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