On January 18, 2019, the mayor of the District of Columbia signed the CleanEnergy DC Omnibus Bill Amendment Act of 2018, increasing the District’s Renewable Portfolio Standard to 100% by 2032 and the solar carve-out to 10% by 2041. Notably, the Act increased the useful life of an SREC from three to five years and drew forward the legacy solar requirement by two years. As a reaction to these policy changes, the District’s SREC market has seen a much-needed jump in both pricing and liquidity, after over a year of falling SREC values and thin market conditions. Since the market bottomed-out in Q4 of 2018 at $295 per credit, we have seen a dramatic pricing swing of nearly 30%, to $380 per credit. The enclosed analysis examines the fundamental market conditions which are driving this increase in market pricing and liquidity.
With the enactment of the CleanEnergy DC Omnibus Bill Amendment Act of 2018, electric load can now be placed into one of three compliance buckets:
- Load contracted prior to October 8, 2016, which is obligated to the provisions in the DG Amendment Act of 2011
- Load contracted between October 8, 2016 and January 1, 2019, which is obligated to the provisions in the Renewable Portfolio Expansion Act of 2016
- Load contracted on or after January 1, 2019, which is obligated to the provisions in the CleanEnergy DC Omnibus Bill Amendment Act of 2018
According to solar alternative compliance payment (SACP) data in the DCPSC Annual RPS Report for Compliance Year 2017, approximately 75% of the District’s 2017 electric load was grandfathered under the legacy SACP levels from the DG Amendment Act of 2011. Based on this information, we made the calculated assumption in our analysis that the percentage of 2019 electric load in each respective bucket is as follows: twenty-five percent (25%) in bucket 1, fifty percent (50%) in bucket 2, and twenty-five percent (25%) in bucket 3. We assumed that bucket 1 would roll off completely by 2020 and bucket 2 by 2022. Beginning in 2022, all load will be subject to the solar requirement and SACP provisions in the CleanEnergy DC Omnibus Bill Amendment Act of 2018.
Using these assumptions and flat load growth moving forward, we will likely see the market shift from an oversupplied to an undersupplied dynamic beginning in 2020. However, even with a near-certain oversupplied dynamic in 2019, the ability to bank credits for five years allows market participants to more flexibly utilize these SRECs, providing buoyancy to 2019 vintage SREC pricing. Barring an unprecedented increase in solar build rate or decrease in statewide electric load served, we expect this policy change to provide SREC pricing stability for the foreseeable future.
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