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DOER Releases Draft of SREC-II Regulations

Posted January 7th, 2014 by SRECTrade.

225 CMR 14.00 Renewable Portfolio Standard Class I Regulations

On January 3, 2014, the Massachusetts Department of Energy Resources (DOER) filed revisions to the 225 CMR 14.00 Renewable Portfolio Standard Class I regulation. The email announcement is available here. The redlined, unofficial version of this draft is available on the DOER website, and the official version of the draft regulation will be published in the Massachusetts Register on January 17, 2014. This filing begins the formal rulemaking process.

The primary objectives of the revisions are twofold: 1) to establish the second phase of the Solar Carve-Out program (the SREC-II program); and 2) to revise the RPS Class I program to address previously identified needs to improve the program design. Next stages for the rulemaking process and a few excerpts of the draft are detailed below.

I. Continuation of Rulemaking Process

A. Public Hearing

The DOER will hold a public hearing on January 24, 2014 from 1:00 to 3:00 pm to receive oral and written comments on the proposed regulations. The hearing will be held at the Gardner Auditorium of the Massachusetts State House in Boston, MA. Parties interested in presenting oral testimony at the hearing are requested to provide written copies of their testimony.

B. Written Comments

Per the DOER: Written comments will be accepted beginning on January 3, 2014 and ending at 5:00 pm on January 29, 2014.  Please submit written comments electronically to DOER.SREC@state.ma.us or to Michael Judge, via mail to the Department of Energy Resources, 100 Cambridge Street, Suite 1020, Boston, MA 02114.

II. Selected Excerpts

A. Eligibility for SREC-II

Section 14.05(9)(b) specifies that a Solar Carve-Out II (SREC-II) Renewable Generation Unit must have a Commercial Operation Date on or after January 1, 2012 and must not be qualified as a Solar Carve-Out Renewable Generation Unit (that is, qualified under the SREC-I program). Section 14.06(4)(c) states that the RPS Effective Date for SREC-II facilities shall be the Commercial Operation Date or the first day following the calendar quarter in which the Unit receives its Statement of Qualification (see Part C. below), whichever is earlier.

Like SREC-I facilities, SREC-II facilities will be issued 40 quarters of SREC-eligibility, based on the SREC factor times the number of MWh generated. The SREC factor assigned to a Unit in its Statement of Qualification (SQA) shall remain its SREC factor for its entire 40 quarters of eligible generation of Solar Carve-Out II Renewable Generation Attributes. Furthermore, the DOER shall complete a review of the SREC Factor Guideline no later than March 31, 2016 to take into consideration market data and analysis as well as external changes in state and federal policies and global markets. Any changes made by these guidelines shall apply to Sectors A-C for units qualified on or after January 1, 2017 and will apply to projects seeking capacity for the Managed Growth Sector in 2018. 14.05(l)4, 5.

chart

 

Any excess of the SREC factor accumulated during the 40 quarters will be retired by NEPOOL-GIS. After 40 quarters of SREC-II eligibility, the system will cease to produce SREC-IIs and will begin producing Class-I credits for 100% of the MWh that the system generates. 14.05(9)(k).

Any solar photovoltaic facility larger than six MW in capacity installed on the same parcel of land and meeting all other requirements under SREC-II may qualify only for RPS Class I Renewable Generation Attributes. 14.05(9)(a). The SREC-II program capacity cap is the aggregate eligible capacity, in MW, of Solar-Carve Out II Renewable Generation Units qualified by the Department equal to 1600 MW minus the Solar Carve-Out Program Capacity Cap. 14.02.

B. Eligibility for SREC-II in the Managed Growth Sector

SREC-II facilities in the Managed Growth Sector will be eligible for qualification subject to several provisions, including annual capacity blocks, which will be announced no later than June 30 of each subsequent Compliance Year for the Compliance Year two years in the future.

  • For Compliance Year 2014, the annual capacity block shall be 26 MW;
  • For Compliance Year 2015, the annual capacity block shall be 80 MW. 14.05(m).

C. Procedure for Applying for an Assurance of Qualification & Financing Opportunities

The DOER will issue a full guideline outlining the process for providing Assurance of Qualification, though the draft revisions did not specify where or when these guidelines will be available. However, the revisions do specify that the content of these guidelines will be subject to stakeholder review and comment.

Section 14.05(o) details that the DOER shall grant an Assurance of Qualification for SREC-II facilities that have either:

  1. been granted the approval to interconnect to the grid by their local distribution company; or
  2. have provided evidence of the following:
    (a)  an executed Interconnection Service Agreement (ISA) with the distribution company; and
    (b)  adequate site control, interest, or other contractual right to construct the system at the location specified in the ISC; and
    (c)  all required governmental permits and approvals to construct the system, including building permits and notwithstanding any pending legal challenge(s) to such permits.

Section14.05(p) confirms that the DOER will establish a program utilizing ACP funds to enhance the availability of ownership financing options for SREC-II facilities. This program will be available for residential and other buildings that are owned by 501(c)(3) organizations who are incorporated under state law as not-for-profit corporations.

D. Solar Credit Clearinghouse Auction-II (SCCA-II)

Below is an overview of the Solar Credit Clearinghouse Auction under the SREC-II program. For the most part, the rules and process are similar to how the auction is run under SREC-I.

The Solar Credit Clearinghouse Auction-II for SREC-II shall be held as follows, pursuant to the draft regulations Section 14.05(9)(f)-(j):

  1. The first auction will be held each year on or before July 31.
    SCCA-II will be available for deposits between May 16 and June 15, inclusive of these dates. A 5% fee will be assessed for all SCCA-II clearinghouse prices, pursuant to the fixed price schedule available below. All SREC-II attributes deposited into SCCA-II will be eligible for two additional years.

    chart acp

    If the first auction clears, then the total amount of re-minted auction-II account generation attributes (SRECs) will be distributed to the bidders in a pro-rated manner based on their bid volume.

  2. If the first auction does not clear, then the DOER will void the auction and conduct a second auction within three business days of the first auction. The SRECs deposited into this auction will be issued eligibility for three subsequent compliance years from the year in which they were generated.
  3. If the second auction does not clear, then the DOER will void the auction and recalculate the Massachusetts Solar Carve-Out II Minimum Standard to adjust the demand before conducting a third auction, which will be held within three business days of the second auction. If this third auction does not clear, then the demand will be reallocated on a pro rata basis, and the excess will be returned to sellers with the previously-issued three year eligibility. These SRECs will be ineligible for future auctions.

E. Renewable Energy Portfolio Standard & Compliance Obligation Formula

The compliance obligation formulas remains the same as under 14.07(2)(d): For each subsequent Compliance Year (CY), the total compliance obligation shall be equal to the total compliance obligation from the previous Compliance Year (CY-1), plus the difference between the Solar Carve-Out Renewable Generation Attributes projected to be generated for the previous Compliance Year and the Solar Carve-Out Renewable Generation Attributes actually generated for the Compliance Year two years  prior (CY-2) which is multiplied by 1.3, plus the number of Solar Carve-Out Renewable  Generation Attributes from the Compliance Year two years prior banked as provided under 225 CMR 14.08(2), plus the number of Solar Carve-Out Renewable Generation Attributes from the Compliance Year two years prior deposited into the Solar Credit Clearinghouse Auction Account.

Total Compliance ObligationCY = Total Compliance ObligationCY-1 + [Total SRECs Generated (projected)CY-1 – SRECs Generated (actual)CY-2] x 1.3 + Banked VolumeCY-2 + Auction VolumeCY-2

The SREC-II Minimum Standard will not apply to the portion of load-serving entities’ (LSEs) energy sales that were subject to electricity contracts signed prior to the implementation of the program, provided that the LSE in the party to the contract provides the DOER with evidence of such contract. 14.07(3)(b).

Section 14.07(3) establishes the SREC-II Minimum Standard, which will be calculated and announced by the DOER not later than August 30 of the preceding Compliance Year as specified in the Section. 2014 and 2015 demand has already been established:

  • For Compliance Year 2014, the total compliance obligation is 41,279 MWh of SREC-II generation by 85 MW of SREC-II capacity across the sectors. 14.07(3)(c).
  • The total compliance obligation for Compliance Year 2015 is 161,958 MWh, generated by 230 MW of SREC-II capacity across the sectors. 14.07(3)(d).

For each subsequent Compliance Year (CY), the total compliance obligation shall be determined by the DOER as equal to the sum of the following quantities of generated and projected SREC-IIs:

  1. Installed SREC-II Supply (installed facilities);
  2. Qualified but not Installed SREC-II Supply (facilities that have been initiated but are not yet online);
  3. Projected New Supply (based on prior growth trends by market sectors and annual capacity blocks, such that cumulative installed capacity does not exceed the cumulative installed capacity target for the end of the year as follows);max capcity table
  4. Rollover Volume (those SREC-IIs that remain eligible for compliance from re-minted SCCA-II generation and banked SREC-IIs); and
  5. Third Round Auction Volume Doubling (in the case of a third round SCCA-II).

Section 14.07(3)(g) assures that the DOER will provide a clear and precise methodology by which it will calculate the quantities set forth above and the Compliance Obligation.

After 2020, the RPS Class I Minimum Standard shall increase by 1% per Compliance Year unless modified by law. 14.07(4).

As the rulemaking process continues, we will provide updates and additional analysis on this blog.

 

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Posted in Massachusetts, SREC Markets |

SRECTrade Markets Report: November 2013

Posted December 23rd, 2013 by SRECTrade.

SRECTrade SREC Markets Report: November 2013

The following post is a monthly update outlining the megawatts of solar capacity certified to create SRECs in the Solar REC markets that SRECTrade serves. All PJM data is based on the information available in PJM GATS as of the date noted. All MA data is based on the information provided by the DOER as of the date noted. This analysis does not include projects that are not yet registered and certified with the entities noted herein.

A PDF copy of this table can be found here.

Capacity_November2013 copy

Overview of PJM Eligible Systems

As of December 4, 2013 there were 39,469 solar PV and 794 solar thermal systems (a 1.4% period-over-period increase) registered and eligible to create SRECs in the PJM Generation Attribute Tracking System (GATS). Of these, 257 (up 1 project since October and representing 0.64% of the total projects installed) have a nameplate capacity of 1 megawatt or greater, but account for 42.43% of the overall capacity registered. Twenty-eight of these projects have a nameplate capacity of 5 MW or greater (an increase of 1 project period over period). New Jersey continues to host most of the larger scale facilities, claiming home to 17 of the 28 facilities, that are equal to or greater than 5 MW. Also, unchanged for several months, the three largest projects are a 29.1 MW FirstSolar project in MD, a 25.1 MW PSE&G utility pole mount project located in NJ, and the 16.1 MW Mount St. Mary’s project in MD.

NJ Office of Clean Energy Estimated Installed Capacity Through 11/30/13: On December 9, 2013, the New Jersey Office of Clean Energy (OCE) announced total installed solar capacity reached 1,168.1 MW; an increase of approximately 13 MW over the total capacity reported at the end of October. The average last six month build rate per month, according to the OCE data, is 11.6 MW.

Massachusetts DOER Qualified Projects

As of December 20, 2013, there were 9,512 MA DOER qualified solar projects; 9,261 operational and 251 not operational. Total qualified capacity is 694.6 MW (an increase of 2.8 MW since our last monthly capacity report); 335.8 MW of which is operational (up 42.3 MW from the DOER’s October 16 report) and 358.8 MW is not operational under the current SREC-I program.

Not operational, qualified projects over 100 kW in size must demonstrate at least 50% of the project’s costs be incurred by 12/31/2013 in order to remain qualified. Note, these totals should adjust as projects less than 100 kW in capacity become qualified throughout the year. Projects less than 100 kW must be interconnected by the effective date of the SREC-II program or June 30, 2014, whichever is earlier. Whereas projects greater 100 kW in capacity must have submitted application paperwork and met certain requirements by July 5, 2013. For more information refer to our blog posts covering the current SREC program.

How to Interpret This Table

The tables above demonstrate the capacity breakout by state. Note, that for all PJM GATS registered projects, each state includes all projects certified to sell into that state. State RPS programs that allow for systems sited in other states to participate have been broken up by systems sited in-state and out-of-state. Additional detail has been provided to demonstrate the total capacity of systems only certified for one specific state market versus being certified for multiple state markets. For example, PA includes projects only certified to sell into the PA SREC market, broken out by in-state and out-of-state systems, as well as projects that are also certified to sell into PA and Other State markets broken out by in state and out of state systems (i.e. OH, DC, MD, DE, NJ). PA Out-of-State includes systems sited in states with their own state SREC market (i.e. DE) as well as systems sited in states that have no SREC market (i.e. VA). Also, it is important to note that the Current Capacity represents the total megawatts eligible to produce and sell SRECs as of the noted date, while the Estimated Required Capacity – Current and Next Reporting Year represents the estimated number of MW that need to be online on average throughout the reporting period to meet the RPS requirement within each state with only that particular compliance period vintage. For example, New Jersey needed approximately 496.7 MW online for the entire 2013 reporting year to meet the RPS requirement with 2013 vintage SRECs only. SRECs still available from prior eligible periods can also impact the Solar RPS requirements. Additionally, the data presented above does not include projects that are in the pipeline or currently going through the registration process in each state program. This data represents specifically the projects that have been approved for the corresponding state SREC markets as of the dates noted.

Note: SREC requirements for markets without fixed SREC targets have been forecast based on EIA Report “Retail Sales of Electricity by State by Provider” updated 10/1/12. Projected SRECs required utilizes the most recent EIA electricity data applying an average 1.5% growth rate per forecast year. The state’s RPS Solar requirement is then multiplied by forecast total electricity sales to arrive at projected SRECs required. Projected capacity required is based on a factor of 1,200 MWh in PJM states and 1,130 MWh in MA, generated per MW of installed capacity per year.

 

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Posted in Capacity Summary, SREC Markets |

Turning the page on 2013: Exciting changes at SRECTrade

Posted December 20th, 2013 by SRECTrade.

A note from our CEO, Brad Bowery:

As 2013 concludes, it marks the end of my 5th and final year at SRECTrade. As we head into 2014, my close colleague for nearly 4 of those years, Steven Eisenberg, will assume the role of CEO. Steven has led our business development efforts and driven the growth of our brokerage desk and I am fortunate to have someone I can trust to take over our business and continue what my partner, Kevin Quilliam, and I have created.

For the 5th consecutive year, 2013 was our best year yet, and prospects look even better for 2014! In the last two years, our products and services have been fully defined, we have put a great team in place and our business has achieved ever-elusive profitability in a highly uncertain solar industry. SRECTrade has evolved from a simple website hosting monthly auctions in 2008 to a full services brokerage desk, online marketplace and SREC transaction management software platform. In early 2014, we will be launching a major overhaul of our entire website. SRECTrade 2.0 is a project started in 2012 to rebuild our entire infrastructure from the ground up. I’m very excited for the launch of the new site as it appropriately reflects the maturity of our business over the past few years.

With the company in good hands and the business in a healthy place, I felt this was a great time to move on to my next adventure. I have a passion for building companies and have at least one more startup in me! In the meantime, I am looking forward to seeing SRECTrade continue to prosper under Steven’s guidance.

Finally, our company wouldn’t be what it is today without help. Over the past 5 years, I’ve been joined by a brilliant business partner, an extremely supportive investor, 6 co-founders, 15 employees, 25 interns, 300 channel partners, 10,000 customers, over 60 energy suppliers and the kind folks at the various state agencies including MA DOER and CEC PTS, PA AEPS and PUC, MD PSC, DC PSC, DE SEU and PSC, NJ BPU and OCE, PUC of OH, PJM GATS, and NEPOOL GIS who have all contributed to making our vision, of a transparent, online platform for transacting SRECs, a reality. In this respect, I have been remarkably fortunate.

I am most proud when I think of our wonderful employees who have stuck with us through thick and thin. In over 5 years, we have turned over just one employee, which is a testament to the work environment that we, collectively, have created! I am also lucky to have been continuously on the same page with a great partner and investor, both of whom have been tremendous assets along this journey. They were particularly incredible throughout the difficult decision to make this transition and I am grateful for all they have done.

Thank you for a great 5 years, and here’s to many more!

Happy Holidays, Merry Christmas and a Happy New Year!

-Brad Bowery

SRECTrade_Tahoe

 

Posted in SRECTrade News |

DOER Commissioner Mark Sylvia’s SREC-II Preview

Posted December 20th, 2013 by SRECTrade.

The Massachusetts SREC market is in the process of switching from the existing SREC-I program to a yet to be officially proposed SREC-II program.  At a meeting held on Friday, 12/13/2013, Mark Sylvia, the Commissioner of the Massachusetts Department of Energy Resources (DOER),  presented a preview of some items we should expect to find in the DOER’s official SREC-II proposal.

In August 2013, the DOER  presented a draft proposal for the SREC-II program with the intention to incorporate feedback from stakeholder groups before presenting a final proposal sometime by the end of 2013. Now that 2013 is nearly done, it’s likely that the formal proposal will not emerge until early January 2014. Once the SREC-II proposal is issued there are several regulatory hoops that the proposal must go through before the program can be put in place. We blogged about the SREC-II implementation timeline in a previous post here and expect the process to take 100 days or more.

Key items learned from Mark Sylvia’s presentation

Items that have not changed from the draft proposal

1) SREC factors and Market Sectors – Depending on project size and other considerations projects will be able to produce SRECs at different rates. Smaller projects receive more SRECs on a per MW-hr basis than larger projects. For example, a residential project will receive 1 SREC for every MW-hr produced, whereas a landfill sited project might receive 0.8 SRECs per MW-hr. SREC factor will be determined by Market Sectors as described below.

Market Sectors

2) Declining Solar Credit Clearinghouse Auction (SCCA) pricing and Alternative Compliance Payment (ACP) rates – The SCCA is the MA market’s price floor mechanism. In SREC-I the SCCA is fixed at a price of $300/SREC, but the SCCA will drop from $300 to $285 starting in 2017 and then drop again on a yearly basis with SREC-II. The SREC-II ACP rate will start at $375 in 2014 and 2015 and decline, beginning in 2016, as shown in the table below.

ACP Schedule

Items that HAVE changed from the draft proposal

1) No Forward SREC Minting
Originally the DOER proposed that residential projects should be eligible to create 10 years worth of SRECs  at the onset of a project. This provision was removed, presumably amid concerns about how to properly track and incentivize SREC production after the upfront issuance and payment is made.
 
2) No Competitive SREC Factor 
All projects are to be assigned fixed SREC factors determined by Market Sector. In the DOER’s draft proposal, projects under the Managed Growth Market Sector (>500 kW and less than 67% on site electricity usage) would competitively offer for a spot to be eligible for the SREC-II program by adjusting the SREC factor. Projects with the lowest SREC factors would be given a spot in the eligible projects queue. This is no longer the case.
 
3) New Grant Program for Directly Owned Residential Facilities 
The Commonwealth Solar II grant program will stay in place until another $30 million program can be implemented using Alternative Compliance Payment (ACP) funds to support direct ownership. Presumably 3rd party leasing / PPA entities will not be able utilize the funds. It was previously expected that the current grant program would end with the sunset of SREC-I.
 
How Much Longer?
In-line with our expectations, the presentation announced the RPS revisions for SREC-II should be filed any day. A public hearing and comment period will follow as well as committee review processes. The DOER projects that the rules will become effective by the end of Q1 2014. We will continue to keep a close eye on the rule making process and provide updates as they are available.

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Posted in Massachusetts |

MA DOER Posts SREC-I Project Extension Guidelines

Posted November 15th, 2013 by SRECTrade.

On November 14, 2013, the Massachusetts Department of Energy Resources (DOER) posted the official, final project eligibility extension guidelines for SREC-I (current SREC program) qualified projects >100 kW in size.*

The official extension guidelines can be found here and the DOER’s email announcing the guidelines can be found here.  Without an extension, the deadline for installing SREC-I eligible projects >100 kW is December 31, 2013. Projects are eligible for an extension if they can prove they have incurred 50% of the cost to construct by 12/31/2013. Extension forms must be filed with the DOER no later than January 13, 2014.

*Projects less than or equal to 100 kW DC in capacity do not need to file for an extension. These projects are eligible for SREC-I provided that they can prove interconnection and have submitted complete program Statement of Qualification Applications (SQA) by the day before the effective date of the start of the SREC-II program. It is expected that the effective date of SREC-II will likely occur sometime on or before the end of Q1 2014.

 

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Posted in Massachusetts |

SRECTrade Markets Report: October 2013

Posted November 12th, 2013 by SRECTrade.

SRECTrade SREC Markets Report: October 2013

The following post is a monthly update outlining the megawatts of solar capacity certified to create SRECs in the Solar REC markets that SRECTrade serves. All PJM data is based on the information available in PJM GATS as of the date noted. All MA data is based on the information provided by the DOER as of the date noted. This analysis does not include projects that are not yet registered and certified with the entities noted herein.

A PDF copy of this table can be found here.

Capacity_October2013

Overview of PJM Eligible Systems

As of November 6, 2013 there were 38,912 solar PV and 790 solar thermal systems (a 1.8% month-over-month increase) registered and eligible to create SRECs in the PJM Generation Attribute Tracking System (GATS). Of these, 256 (0.64%) have a nameplate capacity of 1 megawatt or greater, but account for 42.62% of the overall capacity registered. Twenty-seven of these projects have a nameplate capacity of 5 MW or greater (unchanged from the last several months). New Jersey continues to host most of the larger scale facilities, claiming home to 17 of the 27 facilities, that are equal to or greater than 5 MW. Also unchanged for several months, the three largest projects are a 29.1 MW FirstSolar project in MD, a 25.1 MW PSE&G utility pole mount project located in NJ, and the 16.1 MW Mount St. Mary’s project in MD.

NJ Office of Clean Energy Estimated Installed Capacity Through 10/31/13: On November 7, 2013, the New Jersey Office of Clean Energy (OCE) announced total installed solar capacity reached 1,155.4 MW; an increase of approximately 13.2 MW over the total capacity reported at the end of September.

Massachusetts DOER Qualified Projects

As of October 16, 2013, there were 8,668 MA DOER qualified solar projects; 8,388 operational and 280 not operational. Total qualified capacity is 691.8 MW (and increase of 3.7 MW from the last report); 293.5 MW of which is operational and 398.3 MW is not operational under the current SREC-I program.

Not operational, qualified projects over 100 kW in size must demonstrate at least 50% completion by 12/31/2013 in order to remain qualified. Note, these totals should adjust as projects less than 100 kW in capacity become qualified throughout the year. Projects less than 100 kW must be interconnected by the effective date of the SREC-II program or June 30, 2014, whichever is earlier. Whereas projects greater 100 kW in capacity must have submitted application paperwork and met certain requirements by July 5, 2013. For more information refer to our blog posts covering the current SREC program.

How to Interpret This Table

The tables above demonstrate the capacity breakout by state. Note, that for all PJM GATS registered projects, each state includes all projects certified to sell into that state. State RPS programs that allow for systems sited in other states to participate have been broken up by systems sited in-state and out-of-state. Additional detail has been provided to demonstrate the total capacity of systems only certified for one specific state market versus being certified for multiple state markets. For example, PA includes projects only certified to sell into the PA SREC market, broken out by in-state and out-of-state systems, as well as projects that are also certified to sell into PA and Other State markets broken out by in state and out of state systems (i.e. OH, DC, MD, DE, NJ). PA Out-of-State includes systems sited in states with their own state SREC market (i.e. DE) as well as systems sited in states that have no SREC market (i.e. VA). Also, it is important to note that the Current Capacity represents the total megawatts eligible to produce and sell SRECs as of the noted date, while the Estimated Required Capacity – Current and Next Reporting Year represents the estimated number of MW that need to be online on average throughout the reporting period to meet the RPS requirement within each state with only that particular compliance period vintage. For example, New Jersey needed approximately 496.7 MW online for the entire 2013 reporting year to meet the RPS requirement with 2013 vintage SRECs only. SRECs still available from prior eligible periods can also impact the Solar RPS requirements. Additionally, the data presented above does not include projects that are in the pipeline or currently going through the registration process in each state program. This data represents specifically the projects that have been approved for the corresponding state SREC markets as of the dates noted.

Note: SREC requirements for markets without fixed SREC targets have been forecast based on EIA Report “Retail Sales of Electricity by State by Provider” updated 10/1/12. Projected SRECs required utilizes the most recent EIA electricity data applying an average 1.5% growth rate per forecast year. The state’s RPS Solar requirement is then multiplied by forecast total electricity sales to arrive at projected SRECs required. Projected capacity required is based on a factor of 1,200 MWh in PJM states and 1,130 MWh in MA, generated per MW of installed capacity per year.

 

Posted in Capacity Summary |

Massachusetts SREC-I and SREC-II program updates

Posted November 5th, 2013 by SRECTrade.

The eagerly awaited MA  SREC-II program promises to keep the MA solar industry in over-drive, but when will it start and what happens between now and then? We’ve previously noted in our blog and bulletin emails sent to installers that moving forward SREC-I is separated into two applicant categories. There is still uncertainty about the SREC-II program design and timeline for its implementation, but we know that it may be implemented as early as Q1 2014.

SREC-I Projects 100 kW and Smaller

Projects 100 kW and smaller are eligible for the SREC-I program provided that they are installed and officially interconnected (permission to operate in hand) before the effective date of SREC-II. Our current understanding is that the effective date of SREC-II will likely be sometime after January 2014.

SREC-I Projects Larger than 100 kW

Projects eligible for SREC-I that are not fully interconnected by 12/31/13 must apply for an eligibility extension. Projects are eligible for extensions if they have spent at least 50% of the estimated project construction cost by 12/31/13.

SREC – I extension documents can be found here. Projects registered with SRECTrade should return these documents to us no later than Friday, 12/13/13 to guarantee that SRECTrade can send them to the DOER and confirm their acceptance.

SREC-II Is Still Not Official

We expect the DOER to formally propose the SREC-II program in early November 2013. Once this is done the proposal must undergo several formal review steps including a public comment period and legislative review period. Given these steps we anticipate that the review process will take 100 days or more. Assuming this timeline, the SREC-II program would be effective in February 2014.

Also, be aware that the formal proposal will likely include deviations from the DOER’s initial draft proposal that was submitted in August.

Here are the steps required prior to implementation of the SREC-II program.

Step #1 – File formal SREC-2 proposal with the MA Sec. of State

Step #2 – Hold Stakeholder Meeting in Boston (within 21 days of formal filing)

Step #3 – Assess public comments and post comments on DOER website

Step #4 – Submit Proposal to the Joint Committee on Telecommunications, Utilities, and Energy

Step #5 – Post to DOER website Joint Committee comments (30 days required)

Step #6 – Submit final draft to MA Sec. of State

Step #7- SREC-2 Program effective start (likely 14+ days after final submission to Sec. of State)

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Posted in Massachusetts |

Massachusetts SREC Webinar, Thursday, 11/14 at 2 pm EST.

Posted November 5th, 2013 by SRECTrade.

SRECTrade will host a webinar covering the Massachusetts SREC market on Thursday, 11/14/2013 at 2 pm EST. Sign up for the webinar by clicking here or the image below.

What the Massachusetts SREC webinar will cover:

  1. The close out of the SREC-I program
  2. New SREC-II program rules and steps required for SREC-II to be implemented*
  3. Current Massachusetts SREC supply analysis
  4. Current Massachusetts SREC pricing

*UPDATE- November 12, 2013:  It is unlikely that the DOER will formally propose SREC-II in time for Thursday’s webinar. The DOER is now targeting the end November to formally post the SREC-II proposal. We will still cover the timeline for implementing SREC-II once it is formally proposed.

November 2013 MA SREC webinar

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Posted in Massachusetts, Webinars |

SRECTrade Markets Report: September 2013

Posted October 14th, 2013 by SRECTrade.

SRECTrade SREC Markets Report: September 2013

The following post is a monthly update outlining the megawatts of solar capacity certified to create SRECs in the Solar REC markets that SRECTrade serves. All PJM data is based on the information available in PJM GATS as of the date noted. All MA data is based on the information provided by the DOER as of the date noted. This analysis does not include projects that are not yet registered and certified with the entities noted herein.

A PDF copy of this table can be found here.

Capacity_September2013 copy

Overview of PJM Eligible Systems

As of October 9, 2013 there were 38,219 solar PV and 781 solar thermal systems registered and eligible to create SRECs in the PJM Generation Attribute Tracking System (GATS). Of these, 254 (0.65%) have a nameplate capacity of 1 megawatt or greater, but account for 42.74% of the overall capacity registered. Twenty-seven of these projects have a nameplate capacity of 5 MW or greater (unchanged from the last several months). New Jersey continues to host most of the larger scale facilities, claiming home to 17 of the 27 facilities, that are equal to or greater than 5 MW. Also unchanged for several months, the three largest projects are a 29.1 MW FirstSolar project in MD, a 25.1 MW PSE&G utility pole mount project located in NJ, and the 16.1 MW Mount St. Mary’s project in MD.

NJ Office of Clean Energy Estimated Installed Capacity Through 9/30/13: On October 9, 2013, the New Jersey Office of Clean Energy (OCE) announced total installed solar capacity reached 1,142.3 MW; an increase of approximately 8.0 MW over June’s total capacity.*

*This 8.0 MW month over month increase does not take in to consideration two projects totaling 26.7 MW that the OCE retroactively approved. In effect the overall approved capacity increased by 8.0 MW plus the 26.7 MW retroactive addition.

Massachusetts DOER Qualified Projects

As of September 30, 2013, there were 8,311 MA DOER qualified solar projects; 8,024 operational and 287 not operational. Total qualified capacity is 688 MW; 277.8 MW of which is operational and 410.3 MW is not operational under the current SREC 1 program.

Not operational, qualified projects over 100 kW in size must demonstrate at least 50% completion by 12/31/2013 in order to remain qualified. Note, that these totals should adjust as projects lower than 100 kW in capacity become qualified throughout the year. Projects lower than 100 kW must be interconnected by the effective date of an SREC 2 program or June 30, 2014, whichever is earlier. Whereas projects greater 100 kW in capacity must have submitted application paperwork and met certain requirements by July 5, 2013. For more information refer to our blog posts covering the current SREC program.

How to Interpret This Table

The tables above demonstrate the capacity breakout by state. Note, that for all PJM GATS registered projects, each state includes all projects certified to sell into that state. State RPS programs that allow for systems sited in other states to participate have been broken up by systems sited in-state and out-of-state. Additional detail has been provided to demonstrate the total capacity of systems only certified for one specific state market versus being certified for multiple state markets. For example, PA includes projects only certified to sell into the PA SREC market, broken out by in-state and out-of-state systems, as well as projects that are also certified to sell into PA and Other State markets broken out by in state and out of state systems (i.e. OH, DC, MD, DE, NJ). PA Out-of-State includes systems sited in states with their own state SREC market (i.e. DE) as well as systems sited in states that have no SREC market (i.e. VA). Also, it is important to note that the Current Capacity represents the total megawatts eligible to produce and sell SRECs as of the noted date, while the Estimated Required Capacity – Current and Next Reporting Year represents the estimated number of MW that need to be online on average throughout the reporting period to meet the RPS requirement within each state with only that particular compliance period vintage. For example, New Jersey needed approximately 496.7 MW online for the entire 2013 reporting year to meet the RPS requirement with 2013 vintage SRECs only. SRECs still available from prior eligible periods can also impact the Solar RPS requirements. Additionally, the data presented above does not include projects that are in the pipeline or currently going through the registration process in each state program. This data represents specifically the projects that have been approved for the corresponding state SREC markets as of the dates noted.

Note: SREC requirements for markets without fixed SREC targets have been forecast based on EIA Report “Retail Sales of Electricity by State by Provider” updated 10/1/12. Projected SRECs required utilizes the most recent EIA electricity data applying an average 1.5% growth rate per forecast year. The state’s RPS Solar requirement is then multiplied by forecast total electricity sales to arrive at projected SRECs required. Projected capacity required is based on a factor of 1,200 MWh in PJM states and 1,130 MWh in MA, generated per MW of installed capacity per year.

 

Posted in Capacity Summary |

Washington, DC Update: Community Net Metering Bill Passed by DC Council

Posted October 11th, 2013 by SRECTrade.

The D.C. Council voted to pass Community Solar legislation on October 1, 2013. First introduced on January 8, 2013  the Community Renewable Energy Act of 2013 (CREA),  promises to lower the barrier for going solar and diversify solar market participants by allowing DC ratepayers to subscribe to power from solar facilities that are not located on their property using Virtual Net Metering. Similar legislation has been passed in states like Maine, California, Massachusetts, Vermont, and Colorado. The bill is expected to be signed by the Mayor later this month and will become effective sometime thereafter.

How this might impact Washington, DC SRECs

DC is currently the only under-supplied SREC market. Approximately 288 MW of solar capacity is required by 2023. The 2013 RPS requirement is approximately 49 MW of which only 28 MW have been registered to date in GATS. Currently DC SREC prices are the highest of any SREC market at $480/SREC in recent transactions. And yet, despite the very rich SREC incentive in the District, build rates have been subdued. By opening up the market to more participants it’s possible that build rates and SREC availability will increase at a faster rate, impacting SREC pricing.

Here’s what’s in the Community Renewable Energy Act of 2013

  • Community Energy Generating Facilities cannot be larger than 5 MW in capacity
  • There can be as few as 2 subscribers to the power produced from eligible facilities
  • Subscriptions cannot be for more than 120% of the subscriber’s 12 month electricity usage
  • Subscriber accounts can only be adjusted once a month
  • Utilities (Pepco) may be able to require all subscribers to be on the same billing cycle
  • The owner(s) of the Community Energy Generating Facility owns the rights to SRECs produced from the power
  • Power production will be tracked by a production meter installed by the Community Energy Generating Facility owner
  • In months where subscribers receive credit for more power than they consume the excess power will be credited towards the next month’s electric bill
  • Excess power credits at the end of the annual cycle (ends in April of each year) will be lost and reallocated to rate payers eligible for the District’s Low Income Housing Energy Assistance Program (LIHEAP)
  • Requires adoption of the Interstate Renewable Energy Council (IREC) interconnection standards within 6 months of the bill’s passage.
  • The District Department of Energy and the District Sustainable Energy Utility are required to develop a proposal within 6 months for an equitable and creative program for financing community net metering projects.

 

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Posted in Washington, DC |

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