Adjustable Block Program – SRECTrade No Longer Filing Extensions for Interconnection Deadlines

Posted October 17th, 2023 by SRECTrade.

Due to SRECTrade’s retirement as an Approved Vendor in the Illinois Adjustable Block Program on August 10th, 2022 (see this blog post for more information), extensions will no longer be filed for projects who have not met their interconnection deadlines.

Adjustable Block Program (ABP) projects are awarded a contract after their Part I approval. The project then has 12 or 18 months to provide energization documents and be submitted for Part II approval. In the past, SRECTrade has filed extensions on behalf of projects that required more time. Beginning in November, 2023, any projects that have not been Part II submitted by their deadline will be canceled with SRECTrade. This will result in the forfeit of the application and collateral fees (that are non-refundable once awarded a contract), and will require the project to be resubmitted through a different approved vendor to participate in the ABP program.

SRECTrade will continue to provide services for all applications that are Part II submitted prior to their energization deadline. To help ensure your application is not canceled, please submit any outstanding documents 6 weeks prior to your deadline.

SRECTrade looks forward to continuing service of its Designees and existing clients during the remainder of their participation in the ABP.

First Look at Washington CFS Data

Posted October 2nd, 2023 by SRECTrade.

The first batch of data for the new Washington Clean Fuels Standard (CFS) has been made available by the Washington State Department of Ecology. So far, Ecology has published:

Credit Transfer Reports for July and August 2023

No credits were transferred in July after technical issues with the Washington Fuel Reporting Systems triggered a one-month delay in the first issuance of credits. However, 27,055 credits were transferred in August. The average price from the four reported trades was $106.66. The price of Washington CFS credits was about midway between those reported in CA ($77) and OR ($137) during the same month. Credits from one program cannot be sold in another. 

Q1 2023 Credit and Deficits

Ecology reported 275k credits generated and 227k deficits generated, a net credit build of about 47k credits. Entities with compliance obligations do not have to retire credits until next year, and credits do not expire so they may be held indefinitely by market participants. 

The largest source of credits was ethanol (75%), followed by renewable diesel (12.1%), biodiesel (11.8%), and electricity (10.8%). Credits from residential EV charging, which are separately calculated and issued by Ecology, have not yet been issued for Q1 or Q2.

The deadline for reporting fuel consumption for the Q2 2023 reporting period is today. Ecology has not yet set a publication schedule for reporting quarterly credit and deficit data.

Source: Washington Department of Ecology

What’s Next for the Washington CFS?

Ecology will create a zero-emission vehicle infrastructure or “capacity credit” program for public DC fast-charging and hydrogen refueling stations. Stations approved under this program may generate CFS credits based on the fueling capacity of those stations. Guidance on this program is expected to be released before the end of the year. 

Ecology must also address the inclusion of alternative jet fuel pathways in the CFS after the passage of SB 5447. A rulemaking may be initiated as soon as this year or early next year.

LCFS Changes Likely By Spring 2024

Posted September 18th, 2023 by SRECTrade.

The timeline for implementing changes to the California Low Carbon Fuel Standard (LCFS) became clearer last week. At an industry conference, California Air Resources Board (CARB) Executive Director Dr. Steven Cliff indicated a final proposal would be made available in the “November timeframe” with hopes of approval by next spring. The announcement came after the September 8 publication of the Standardized Regulatory Impact Assessment (SRIA).

Under this timeline. CARB could implement a mid-year adjustment to the 2024 carbon intensity targets, increasing compliance obligations for fuel suppliers. An even more significant adjustment or “step down” is being considered for the 2025 targets, as indicated in the SRIA. The document evaluated other significant changes to the program, including a target acceleration mechanism, the inclusion of intrastate fossil jet fuel as a regulated fuel, and the phasing out of biomethane and forklift crediting. However, Dr. Cliff reiterated that the SRIA, which precedes any formal rule-changes to be considered by the regulatory body which oversees the LCFS, “is not the final proposal. It’s not even the proposal.” 

Source: CARB Standardized Regulatory Impact Assessment for LCFS 2023 Amendments

What To Watch For Next

Regulatory staff will present on changes to the LCFS at the September 28 CARB non-voting meeting. The next formal milestone will be the publication of a Rulemaking Package which starts the 45-day public comment period, after which CARB may adopt new provisions to the LCFS rules. 

Source: CARB Staff Presentation at 9/14 EJAC Committee

LCFS Workshop Hints at Future Changes to Program

Posted August 16th, 2023 by SRECTrade.

The California Air Resources Board (CARB) held a workshop on August 16 to present updates to a model that assesses the feasibility and economic impact of proposed changes to the Low Carbon Fuel Standard (LCFS). Although the workshop did not specifically address policy changes, the inputs of this model are suggestive of what CARB may put forward in formal rule changes coming later this fall.

Why is CARB making changes to the LCFS?

The last time significant changes to the LCFS were made was in 2018. Since then, the agency has workshopped several policy and procedural changes and received significant stakeholder and community feedback. During workshops held last summer, CARB presented a plan to align LCFS with several key climate policies, most notably the 2022 Scoping Plan, which was formally adopted in December 2022.

Key Program Changes 

The model inputs included many of the policy changes that have been discussed at public workshops over the past 18 months and may hint at what the agency will propose later this year. Some of these changes are highlighted below:

Accelerating Carbon Intensity Targets

Carbon intensity, a measure of lifecycle emissions of a fuel, is used as a benchmark to compare gasoline, diesel, and other low carbon fuels such as biofuels and electricity. The benchmark decreases each year to meet the current target of 20% reduction from 2010 levels by 2020. As the benchmark decreases, conventional gasoline and diesel generate more deficits (i.e. greater demand for credits) which produces the long-term incentive for lower carbon fuels.

Reduction in CI Benchmark Over Time

CARB has proposed advancing the 2030 target to between 25% and 35% reduction, while adding a 2045 target of 90% reduction. The 2030 acceleration is significant because it would increase the demand for credits in the near term, depending in part on how the targets “step down” from their current levels in order to meet the new 2030 target. Proponents of steeper 2030 targets argue this will provide needed price support for the LCFS credit market which has significantly declined in recent years due largely to an oversupply in credits. Others caution that overly stringent targets would increase fuel prices and could undermine political support for the program.

In the latest iteration of the model, CARB included a 30% reduction target for 2030 with a significant step down between 2024 and 2025. While not an official proposal from CARB, it might indicate what the agency is ready to move forward with in the fall.

CI Adjustment Mechanisms

Source: California Air Resources Board

Phasing Out eForklifts

In previous workshops, CARB has proposed reducing and eventually phasing out credit generation from eForklifts. Staff discussed reducing the credit generation potential of lighter classes of forklifts and requiring electricity consumption to be metered. Forklifts are unique in that CARB allows for electricity consumption to be estimated. However, both the Oregon Clean Fuels Program and the Washington Clean Fuel Standard have recently required metering for electric forklifts in their programs. CARB’s latest model included a significant reduction in credits from forklifts, suggesting these changes are still on the table.

Verification Requirements for Electricity Credits

In a previous workshop, CARB proposed requiring all participants generating credits from electric vehicles to go through an annual verification process. Electricity is the only major credit source where fuel consumption reporting is not required to be independently verified. Other programs, such as the Canadian Clean Fuel Regulations require verification for all fuel types. 

Expanding Infrastructure Crediting to Medium/Heavy-Duty Vehicle Charging

Under the LCFS, some public fast-charging stations are eligible to generate credits based on the total capacity of the site, not solely on electricity consumption. CARB has proposed expanding these provisions to stations that provide charging to multiple medium and heavy-duty fleets. CARB’s latest model included credit generation from this pathway, suggesting that the agency is still considering this change. 

What’s Next for LCFS?

During the workshop, staff shared an updated timeline which confirmed that formal changes to LCFS will not be considered for adoption until early 2024. However, the agency expects to move forward with the formal rulemaking process later this fall, and implement the changes “sometime in 2024.” 

California LCFS – Q1 2023 Report Highlights

Posted August 7th, 2023 by SRECTrade.

The California Air Resources Board (CARB) published quarterly program data for the Low Carbon Fuel Standard (LCFS) on June 30, 2023 and announced another workshop for August 16 to discuss changes to the program.

Credit Bank Adds 1.3M Net Credits After Sluggish Q1

The cumulative credit bank, a measure of net credit generation over the lifetime of the program, grew for an eighth consecutive quarter and now stands at 16.5M credits. Deficits were down in Q1 (-3%), driven largely by a decline in gasoline volume (-9%). Credits from all sources (-6%) fell for the first time in 2 years driven in part by reductions in volume from electricity (-5%), biodiesel (-3%), and ethanol (-2%). Average carbon intensities (CI) were up across the major credit sources as well, including RNG (+21%), biodiesel (+8%), RD (+9%), and electricity (+3%). Finally, the more stringent CI targets for 2023 kicked in, which reduces the number of credits per unit of low carbon fuel when compared to 2022.

EV Credits Take a Step Back in Q1

Credits from electricity fell last quarter (-7%) for the first time since the COVID pandemic, driven primarily by a 12% decline in residential EV charging credits which are issued to utilities based on a formula. Credits also decreased across other categories including eForklifts (-1%), ocean-going vessels (-13%) and fixed-guideways (-11%). EVs still remain the second largest source of credits under the LCFS and among the fastest growing fuel type.

What’s Next for CA LCFS?

CARB scheduled a workshop on August 16 to present updates to their model that is used to assess the feasibility and economic impact of proposed changes to the program, including establishing more stringent 2030 CI targets. In the previous workshop held in May, CARB staff had reiterated their intent to initiate a formal rulemaking process to make changes to the LCFS by this summer, with a targeted implementation date of January 1, 2024. 

CARB will release Q2 2023 program data by October 31, 2023.

California LCFS – Q4 2022 Report Highlights

Posted May 9th, 2023 by SRECTrade.

The California Air Resources Board (CARB) published quarterly program data for the Low Carbon Fuel Standard (LCFS) on April 28, 2023. In this piece, we will provide some analysis of the new data and highlight interesting trends. 

Credit Bank Growth Slows 

The cumulative credit bank, a measure of net credit generation over the lifetime of the program, grew for a seventh consecutive quarter to reach a new program high of about 15M MT. However, quarter-over-quarter credit growth slowed to 2% while deficits rose by 5%, resulting in a net build of 1.65M MT, slightly lower than last quarter’s build of 1.76M MT and halting a three-quarter trend of growing credit builds.

Source: CARB

Q4 2022 Credit Trends

  • Renewable diesel (RD) rebounded from a rare quarterly decline in Q3, growing by 7% to a new program high of 2.5M MT. RD remains the largest source of credits under the program at 36%.
  • Renewable natural gas (RNG) volumes dropped by about 2% but remains the lowest average carbon intensity (CI) fuel at -119 gCO2e/MJ. Notably, a bill was introduced that would direct CARB to restrict dairy digesters from generating credits under the California program. 
  • Credits from ethanol declined by 5%, while credits from biodiesel and hydrogen both dropped by 4%.

Source: CARB

EV Credit Growth Also Slows

Credits from electric vehicles represented one-quarter of all credits under the program but grew by only 66k MT last quarter, the least since Q4 2021. The distribution of credits across the categories of eligible EVs remains unchanged: residential (49%), eForklifts (23%), and non-residential light/medium-duty (15%). Notably, credits from heavy-duty EVs grew by 10% while credits from electric cargo handling equipment and electric refrigeration units both fell by about 5%. 

Source: CARB

An Update about 3G Meter Replacements in New England

Posted April 6th, 2023 by SRECTrade.

Throughout 2022, the three major US cell phone carriers began to retire their 3G radio bands. Many sites in the SRECTrade aggregate utilized a 3G connection to report monthly kWh production data and were unable to auto-report. 

SRECTrade collaborated with Enphase Energy’s 365 Pronto Platform to provide our clients with a solution to replace their existing 3G meter with a new meter, allowing them to auto-report once again. Clients were able to purchase new meters through the 365 Pronto Platform from Fall 2021 through November 9, 2022. As of February 15, 2023, a majority of affected sites have had their meters replaced and have resumed reporting to the Massachusetts Clean Energy Center’s Production Tracking System (MA PTS). 

Moving forward, clients need to ensure their site continues to report by monitoring their MA PTS accounts and checking for email communications from SRECTrade regarding their site’s data connection to MA PTS. Any inquiries regarding system performance/diagnostics need to be addressed by your system installer or another installer familiar with the on-site equipment (MA PTS installers). 

FAQs:

  • My site resumed reporting but not all production was captured while I was offline. What happens now?
    • A: Unfortunately, it is possible that your system’s production will not be recovered before your new meter installation is reflected in your SRECTrade account. Unless there was another issue present with your system during mid-late 2022,  you will only receive SRECs for your production that was reported successfully after your meter swap was completed.
  • Why has my meter swap not been completed after purchasing a meter and installation service through the 365 Pronto Platform?
    • A: The 365 Pronto Platform team has confirmed that multiple sites still have ongoing installs. 
  • I was cc’d on an email to PTS regarding the meter swap. Why was I included?
    • A: SRECTrade has been sending meter swap notifications to MA PTS to have sites that had a recent swap be able to capture any data from between the old meter going offline and the new meter going online on the day of the swap. MA PTS prefers to have site owners included in email communications regarding their on-site meter. 
  • I purchased a new meter and installation service through the 365 Pronto Platform, but my site has still not resumed reporting to MA PTS. What are the next steps?
    • A: If you have completed a meter swap but noticed no production reflected in MA PTS or have not been included on a meter swap email, then your meter or system is likely offline and needs troubleshooting. We recommend you check with your system’s original installer or check the list of approved installers from MA PTS to troubleshoot your system and have it resume production to MA PTS.  
  • My utility bill is larger than expected. What do you recommend?
    • A: Most of the systems that completed a meter swap were installed 5-10 years ago. A majority of systems are built on historical usage from past utility bills and now in 2023, your energy needs may have changed. We recommend you check with your system installer to be sure your existing system still fits your energy needs. 
  • Still have questions?

New Policy for Adjustable Block Program (ABP) Change of Ownership Process 

Posted April 4th, 2023 by SRECTrade.

SRECTrade has changed our policy regarding the distribution of IL ABP Change of Ownership paperwork. Effective immediately, SRECTrade will be the sole distributor of all IL ABP Change of Ownership paperwork (excluding the Voided Check, Settlement Statements, Divorce Decrees, Death Certificates, and/or Deeds) to clients via RightSignature.

As a result, Designees and other third parties are no longer permitted to distribute IL ABP Change of Ownership paperwork to clients. If you are notified of a home sale, please notify us so we can provide the paperwork to the respective parties once we have all necessary contact information from the buyer.     

By implementing this change, we aim to reduce the confusion around the IL ABP Change of Ownership process and ensure clients have the correct paperwork. As you may be aware, GATS periodically releases new IL ABP Change of Ownership forms, and it is crucial that clients receive the most up-to-date paperwork. 

We appreciate your cooperation in adhering to this new policy. If you have any questions or concerns, please do not hesitate to contact us.

District of Columbia Passes B24-0950 – Local Solar Expansion Amendment Act of 2022

Posted March 23rd, 2023 by SRECTrade.

On March 10, 2023 B24-0950, which was codified as Law Number L24-0314, went into effect. The Solar Renewable Energy Portfolio Standard (RPS) target increased from 10% to 15% by 2041. The Alternative Compliance Payment (ACP) schedule was also adjusted. 

The DC SREC market has experienced unstable conditions due to oversupply and lack of liquidity over the last two years. The RPS increase and the more gradual step-down of the ACP will address these issues and lead to a more stable market. These changes will provide more price stability within the SREC market and increase investor confidence. Current market prices and requirements can be found on our website

SRECTrade was proud to work with solar companies and other stakeholders in support of this bill. Monitoring market conditions and supporting legislation that benefits our clients and partners is one of our highest priorities. 

California LCFS – Q3 2022 Report Highlights

Posted March 9th, 2023 by SRECTrade.

The California Air Resources Board (CARB) published quarterly program data for the Low Carbon Fuel Standard (LCFS) on January 31, 2023. In this piece, we will provide some analysis of the new data and highlight interesting trends. 

But First: What is the Credit Bank and Why is it Growing?

Each quarter, CARB issues credits and deficits based on the carbon intensity (CI) and volume of fuel reporting under the program. The cumulative credit bank, a measure of net credit generation over the lifetime of the program, is often used as a proxy for credit supply and demand. This credit bank grew for the first few years of the program, reaching about 10M MT by the end of 2016. From 2017 through the first half of 2021, the credit bank remained largely stable as quarterly net gains were balanced by quarterly net reductions. However, the credit bank has increased significantly since then, reaching about 13.5M MT according to the latest data.

The immediate reasoning behind the growing bank is simple:

  1. An increase in the production and use of low carbon fuel, which creates credits
  2. A simultaneous decrease in the use of gasoline and diesel, which creates deficits

The forces behind these trends are much more complex, but the LCFS is itself one of those forces. For example, the production of renewable diesel (RD) is incentivized by LCFS and now makes up almost 40% of the diesel fuel reported in the program. RD displaces the use of conventional diesel which would otherwise create deficits. As more RD is produced, more credits and fewer deficits will be generated each quarter. And RD happens to be the single largest source of credits in the program, making up about ⅓ of all credits last quarter.

Of course, RD is not the only fuel generating credits and contributing to the growing credit bank…

Q3 2022 Credit Trends

  • The largest quarter-over-quarter increases came from renewable natural gas (10%), ethanol (6%), and electricity (6%).
  • RD declined slightly (-3%) for the first time since 2020
  • The primary driver of credit growth from renewable natural gas (RNG), the third largest credit source in the program, has been declining average CI. While RNG volume is only 7% up from the same quarter last year, the average CI is now -111 gCO2e/MJ compared to -60 last year. The lower the CI of a fuel, the greater number of credits it will generate.

Spotlight on EV Credits

Credits from electric vehicles continue to be a major source of growth in LCFS, reaching a record share of credits generated Q3 2022 (24%). Consistent with previous quarters, almost 90% of credits from EV charging came from just three categories: residential (49%), eForklifts (23%), and non-residential light/medium-duty (15%).

CARB is expected to release Q4 2022 data by April 28, 2023.