Archive for May, 2018

SRECTrade to speak at EMA Regional Roundtable – May 31, 2018

Posted May 30th, 2018 by SRECTrade.

SRECTrade’s CEO, Steven Eisenberg, will be speaking at the Environmental Markets Association (EMA) Regional Roundtable on Thursday, May 31st in Houston, TX. The panel, Legislative Moves and How they are Changing the Dynamics of the Marketplace for PJM RECS, will be from 3:00-3:30 p.m.

Steven will discuss the Pennsylvania and Maryland Renewable Portfolio Standards’ SREC carve-outs. This panel will cover how legislative changes over the last year created different market dynamics that have affected the SREC market and also the Class I market.

A full conference agenda can be found here.

Pennsylvania SREC Market Update

Posted May 29th, 2018 by SRECTrade.

The Pennsylvania Solar Renewable Energy Credit (SREC) market has been through some changes since the fall of 2017. In October 2017, Governor Wolf signed Act 40 into law. On May 3, 2018, the PA Public Utilities Commission entered its final implementation order. The order clarified two main items:

  1. PA certified SRECs issued for October 2017 generation and prior would maintain their PA SREC certification regardless if the generator was sited in the state or out of the state
    • Out of state generators with RECs generated from November 2017 onward were reclassified as PA Tier I eligible. The PA program administrator and PJM GATS made these updates in the tracking registry in early May 2018.
  2. Some out of state generators would be eligible to temporarily maintain SREC eligibility if their SRECs were sold under a preexisting contract, executed before Act 40 became law. For the generator to maintain eligibility the contract would have to be signed directly with an Electric Distribution Company (EDC) or Electric Generation Supplier (EGS). The contracting EDC or EGS would need to file a petition for approval with PUC within 60 days of the May 3, 2018 final implementation order. If approved, the out of state generator would only be able to maintain PA SREC eligibility for the term and quantity of the contract.
    • On May 17, 2018, the PA PUC issued a follow on order that they will be taking into consideration comments filed by Community Energy to reconsider the requirements of who generators are contracted with in order to maintain PA SREC eligibility for out of state solar projects. Additionally, the PA PUC noted that it would stay the 60 day period for EDCs and EGSs to petition to qualify their contracts with out of state generators, pending further review and consideration of the comments filed by Community Energy. All PA PUC documents and comments can be found by searching Docket #2017-2631527 on the PA PUC site.

One of the most meaningful components of these changes in the PA SREC market has been the change in the price of PA SRECs. The spot market has increased more than 2.5x since this time last year (i.e. from ~$5/SREC in May 2017 to ~$13/SREC in May 2018). Pricing on a forward basis has also been positively impacted with more participants starting to show interest in transacting out the curve.

Fundamentally, the PA SREC market remains oversupplied. A very large bank of eligible SRECs from RY2016, 2017, and 2018 from sited and out of state projects (generation from October 2017 and prior) is the main driver of oversupply. Additionally, Pennsylvania’s solar carve-out is relatively small (0.50% by reporting year 2021) as compared to Maryland’s current 1.5% requirement in calendar year 2018 and New Jersey’s 3.2% requirement in reporting year 2018. For more specific details on potential supply scenarios click here for our latest PA SREC Market Update presentation.

Expected oversupply for reporting year 2018 is by nearly 2 million SRECs. While the analysis shows the oversupply becoming less meaningful moving forward, assuming relatively modest in-state build rates, the market could still expect varying degrees of oversupply (i.e. ~40-70% even in reporting year 2023). One potential factor that could change this oversupply dynamic dramatically would be market participants willingness to purchase PA certified out of state SRECs from the existing SREC bank (i.e. generation from October 2017 and prior). Since the PA PUC final implementation order has been clarified and PJM GATS and the PA AEPS administrator adjusted the SRECs in the tracking registry, demand for in-state SRECs has been much more prevalent than for out of state certified SRECs. The presentation enclosed herein includes a scenario demonstrating what supply would look like relative to demand if none of the out of state certified bank from October 2017 generation and prior were used in meeting current and future RPS obligations. It does not appear likely that this preference for in-state only demand would remain prevalent for a long period of time. It has been presented simply to show a scenario that would lead to one scenario of under-supply that would likely be recognized by the market and quickly corrected.

Lastly, due to the PA PUC staying the petition to qualify of out of state PA forward contracts for continued eligibility during the contract term, it is still unknown how these contracts will impact future supply. The enclosed analysis notes that this has not been taken into consideration in the scenarios presented herein, but please keep this in mind as you are reviewing this information.

As more updates become available we’ll provide more information. Should you have any questions about the enclosed analysis or need REC transaction and management services, please contact us.

NJ Gov. Murphy Signs AB-3723 / SB-2314 Increasing State RPS

Posted May 25th, 2018 by SRECTrade.

On Wednesday, May 23rd, New Jersey Governor Phil Murphy (Dem) signed Assembly Bill 3723 (AB-3723) and Senate Bill 2314 (SB-2314), increasing the state’s Renewable Portfolio Standard (RPS) requirements. The bill establishes renewable energy goals of 21 percent by 2020, 35 percent by 2025, and 50 percent by 2030, making the New Jersey RPS one of the highest in the nation.

Notably, the state’s solar carve-out requirement is raised and accelerated to 5.1 percent of total electricity sales by EY2021 before beginning to ramp-down in 2024. The requirement ramps down in consideration of solar facilities that will be reaching the end of their 15-year SREC production eligibility term.

On the other hand, the bill lowers the solar alternative compliance payment (SACP) schedule to $268.00 in EY2019 with an additional $10.00 reduction each following year.

The bill also shortens the 15-year period that qualified solar projects can generate solar renewable energy credits (SREC) to ten years, effective for all New Jersey SREC Registration Program applications received as of the enactment date. Lastly, the bill mandates that the current SREC program be closed upon reaching the 5.1 percent target and no later than June 1, 2021. It is anticipated that a supplemental “SREC-II” program will follow shortly after the closure of the first program.

The bill also introduces other clean energy initiatives, including:

  • Community Solar: establishes the Community Solar Energy Pilot Program to allow utility customers access to solar projects that are located away from their properties, but within their utility’s service territory. The pilot program is planned to be converted to a permanent community solar program within 36 months.
  • Energy Efficiency: requires individual utilities to implement energy efficiency measures to reduce electricity usage by 2 percent and natural gas usage by 0.75 percent.
  • Energy Storage: mandates Gov. Murphy’s goal of achieving 600 MW of energy storage by 2021 and 2,000 MW by 2030.
  • Offshore Wind: establishes a goal of 3,500 MW of offshore wind by 2030 that will be supported by an offshore wind renewable energy credit (OREC) program.

Simultaneously, Gov. Murphy signed Executive Order No. 28, requiring state agencies to update the Energy Master Plan (EMP) that prepares a strategy for achieving 100 percent clean energy by January 1, 2050. The new EMP is scheduled to be finalized and published by June 1, 2019.

For more information on the bill and its passage through the New Jersey legislature, please visit our previous blog post on the topic here. SRECTrade expects to publish a detailed New Jersey supply and demand analysis reflecting this new legislation soon.

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