Solar Thermal SRECs in DC – Update

Posted November 12th, 2010 by SRECTrade.

The Washington D.C. Public Services Commission has recently clarified the requirements associated with registering Solar Thermal facilities to be eligible for the D.C. SREC market.

Moving forward, all eligible systems must be certified by the Solar Rating and Certification Corporation (SRCC). Specifically, the system has to be SRCC OG-300 certified.

The Washington D.C. Public Services Commission has indicated that any changes to the eligibility requirements would have to be made by the legislature, not the public services commission.

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PA’s Latest Attempt to Increase Solar Requirements – HB 1128

Posted November 12th, 2010 by SRECTrade.

At the end of September, Pennsylvania lawmakers introduced HB 1128. The main focus of the bill is to amend the requirements under PA’s Alternative Energy Portfolio Standards (AEPS) by increasing the amount of renewable energy to come from Tier I alternative energy sources and Solar Photovoltaic technologies. In addition to increasing the requirements, HB 1128 attempts to amend the program by introducing a fixed alternative compliance payment (ACP) for the Solar PV portion of the AEPS. Currently, the ACP under the PA solar carve-out is derived based on 200% of the average SREC price paid by buyers during the reporting year. The ACP in RY2008 and RY2009 was $528.17 and $550.15 per MWh, respectively. The table below demonstrates the the key changes to the solar requirements, attempting to increase the total requirement 3 times the current level by the 2022 energy year.

Positive Impacts of HB 1128
The increase in PV capacity would help support the growing solar economy in Pennsylvania and provide more room under the current requirements for more solar to come to market. The current PA market has over 2,900 solar projects registered and eligible for the AEPS program. The total nameplate capacity of these projects is equal to 51.8 MW. Of these 2,900 projects only four projects are greater than 1 MW. In addition to being eligible for the PA SREC market, many of these facilities could also be registered in other states such as Ohio and Washington D.C.

The current capacity of solar projects eligible for the PA market is greater than the requirements for the current energy year. The implementation of HB 1128 would allow for the solar market to continue to grow and support the development of projects of all sizes, from small rooftop residential to larger multi-MW utility scale solar systems. Pennsylvania’s inability to implement some sort of amendment to increase the solar RPS requirements could result in a migration of PA’s solar industry to other surrounding states such as New Jersey, Maryland, and Delaware which have all recently increased the requirements of their solar RPS programs and maintain fixed alternative compliance payment schedules. It has been estimated that the increase in the AEPS program could create at least 14,000 jobs over the next ten years. A stronger solar policy in PA will not only help create new, clean energy focused jobs, but will help move the state towards a more energy independent future.

Compared to HB 2405, the treatment of out-of-state facilities is not addressed in HB 1128. Though the future acceptance of out-of-state facilities can be left up to the lawmakers to debate, the major problem with HB 2405 was that it excluded existing facilities from neighboring states that have been financed based on being accepted into the SREC program in Pennsylvania. This disregard for the existing out-of-state facilities is unacceptable. Fortunately, HB 1128 does not address this issue. Any future Bill to address this topic should at the very least grandfather in any previously approved facilities.

Negative Impact of HB 1128
Despite the need for an increased requirement, PA HB 1128 may not be the answer because of the low ACPs that are included in the Bill.  It could depress SREC market pricing to levels that could be prohibitive to the economics of solar today.  There are few financeable projects at SREC values below $200, especially when there is limited access to long-term contracts. Compared to other state markets, PA would have the lowest ACP and be heading in the opposite direction of states like Delaware, Maryland and New Jersey that have increased the fines to encourage growth and discourage electricity suppliers from paying the ACP.

Pennsylvania’s Current ACP
Meanwhile, the current ACP in Pennsylvania has not been implemented the way it was intended, which could have an impact on the market in the long run.  The way the law was written, the intent was to fine electricity suppliers 200% of the average SREC purchase price in the PJM region. i.e. keeping them in check with neighboring state markets.  Most likely because this was somewhat vague and difficult to calculate, the ACP was interpreted differently by the organizations implementing the program. Instead of being fined based on neighboring state markets, the interpretation of the ACP was that since Pennsylvania accepted SRECs from throughout the PJM region, it was a fair indication of the average price in the region. Therefore, Pennsylvania uses an ACP of 200% of the average price paid for compliance in Pennsylvania. Instead of keeping buyers in the PA market in check with other states, the ACP in Pennsylvania keeps buyers in check with themselves. The goal for buyers in Pennsylvania is to keep the average price down, so that the fines will remain low in non-compliance years. In reality, the price paid will ultimately have to be just enough to get a project done, though the market would be far more stable if the ACP were implemented as it was originally intended.

Click here for a link to the HB 1128 summary.

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Why other states should take note of the Massachusetts SREC program

Posted November 8th, 2010 by SRECTrade.

On the heels of the Conference On Clean Energy in Boston last week, it is worth drawing attention to the Massachusetts SREC program. Though the market is still in the very early stages of development, the program has been well-conceived and one that may serve to be a template for future SREC markets. (And yes, SREC markets are coming!)

Solar is nothing new to Massachusetts, but SRECs were only introduced in 2010. Prior to the solar carve-out, solar owners had to rely on large upfront incentives and the sale of Class I RECs that had limited value.  The solar carve-out set the stage for an SREC program that will provide a market-based incentive to help subsidize the cost of solar today. Though any homeowner or investor would prefer an upfront cash grant from the state for their solar system, the reality is that both society and the industry have suffered from a reliance on these programs that are at the same time costly and incredibly volatile in availability. The beauty of the SREC program is that it creates a market-based subsidy that is not paid out by the state government, but by the electricity companies that supply the state. Though the price paid for SRECs may vary, the payments made to solar owners for SREC sales can be viewed as a tax levied on the suppliers of dirty energy. As such, once implemented, the program does not require the additional allocation of state funding to subsidize projects. As solar proliferates in the state, the market-based SREC price will come down over time. Meanwhile, solar businesses that adapt to the SREC program will find comfort in the continuity it provides, especially after years of boom and bust periods driven by upfront subsidies.

This fluctuating SREC price is at the heart of the greatest challenge that participants in the solar industry face when confronted with an SREC market. Addressing this uncertainty is precisely why Massachusetts stands out from any other SREC market in the U.S.  Instead of setting fixed long-term targets that may or may not be achieved, Massachusetts has set up a formula that publishes a new target each year based on the conditions in the market the previous year. This formula is designed to ensure that the state is setting goals that are neither too aggressive nor too weak.  As a result, it should be easier for developers to finance solar projects based on the price of SRECs.

This is very different from what we’ve seen in other states. In New Jersey, the state goals increased so aggressively that the market could not keep up and SREC values remained high. This isn’t entirely a bad thing for New Jersey since the state earned ~$700 for each SREC that electricity companies fell short last year. Though that money was intended to fund clean energy projects, Republican Governor Christie was able to use it to balance the state budget. Although the next few examples highlight the opposite extreme, the shortfall in New Jersey in 2010 could very easily happen to any of the other SREC states 5 years from now. At about 255 MW required this year, New Jersey dwarfs every other state that followed in implementing a program.

In the smaller state markets, the problem in the early years is the disproportionate impact that a large project could have on a single market. In 2009 the Delaware market was threatened by a 14 MW Delmarva project that would have collapsed state SREC pricing if it weren’t for state intervention.  Meanwhile, in the next few years, the announcement by AEP of a 50 MW project in Ohio could place a significant burden on the in-state solar industry that only has about a 45 MW requirement for 2011. New Jersey was able to protect the SREC program in the early years by placing a 2MW maximum on qualification. It lifted that restriction in 2010 to feed the exponential growth needed to meet the RPS solar requirement. Hopefully Ohio, Pennsylvania and the other budding state SREC markets realize the impact these large projects will have on a solar industry that is just learning to thrive off of SRECs.

Meanwhile, back in Massachusetts, it seems the state has already thought through a lot of these issues. The aforementioned formula for determining the requirement each year provides certainty that an influx of large projects won’t collapse SREC pricing for everyone else.  In addition, though it recently raised the cap on system sizes from 2 MW to 6 MW, the cap should be enough to ensure that an industry is built, not a few large solar farms. Finally, in case the flexible requirement and 6 MW cap weren’t enough to help participants feel comfortable, the state implemented a program with a floor price of $300 per SREC.  As a result, SRECs in Massachusetts will trade between $300 and $600.  In the unlikely event that there is an oversupply, the state will host a fixed-price auction that will give buyers a chance to purchase the SRECs at $300 to get an early start on the next year. If the SRECs don’t sell after a couple rounds, the state will put them back into the market with an extended life, while at the same time, increasing the requirements proportionally.

In summary, if all goes as planned with the Massachusetts solar carve-out, the state requirement should increase enough each year so that there is never an oversupply.  In the event that there is an oversupply, the state will host an auction for buyers at $300.  If any SRECs go through the auction unsold, the state will increase the requirements to make sure that buyers will be willing to pay more than $300 for them.  For someone looking for certainty in SREC prices, a gaping oversupply will be very unlikely, an unsuccessful last-chance auction will be extremely rare, and if both those scenarios exist, the possibility that a buyer is not willing to pay at least $300 per SREC is unimaginable under the rules put forth by the state of Massachusetts.

Hopefully all the other SREC states, current and future, take note of the Massachusetts Solar Carve-Out.

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Connecticut election results bode well for the future of CT SRECs

Posted November 8th, 2010 by SRECTrade.

After passing both the state house and senate earlier this year, Connecticut’s energy bill 493 was vetoed by outgoing Governor Jodi Rell. The SREC legislation included in the bill was put on hold at the time. After a close election last week, Connecticut Democrat Dan Malloy will likely bring the energy bill back, with specific support for the SREC legislation. Malloy’s support for the bill was stated and evident during his campaign because it created new jobs and moved towards clean energy.

Malloy also stated on his website that he is committed to “expand[ing] opportunities to finance and invest in energy efficiency and renewable energy”. When asked about the current law that attempts to make 20% of Connecticut’s energy come from green sources, Malloy wrote, “Achieving this “20 by 20″ renewable energy goal would go a long way to reducing costs while also improving our environment and Connecticut’s quality of life”.

This is a very positive sign for the Connecticut solar industry, one that has suffered the highs and lows of inconsistent grant and rebate funding from the state government.  The addition of an SREC market would provide the type of stability that solar companies have thrived on in Massachusetts, New Jersey and other states that have moved towards the market-based incentive program.

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Twitter Weekly Updates for 2010-10-24

Posted October 24th, 2010 by SRECTrade.

Important New York SREC Update

Posted October 20th, 2010 by SRECTrade.

Good news for New York solar owners: SRECTrade was recently notified by the DC Public Service Commission that they are now accepting SRECs from facilities located in the state of New York.  We initially wrote about this several months ago and submitted applications that were subsequently rejected due to an inconsistency in the DC rules.  This inconsistency has been fixed and New York facilities can now be approved. In order to apply, your facility must be eligible to claim ownership for the SRECs that are generated (NYSERDA claims ownership of SRECs created by facilities funded by the program for a period of 3 years, after which the owner is eligible to generate and sell SRECs).

The bad news… act soon: Per the rules of the DC SREC programs, facilities are able to receive credit for generation dating back to the first month of the current energy year.  In order to receive credit for generation in 2010, all applications should be submitted to the DC Public Service Commission as quickly as possible so that the Commission has ample time to approve your facility by December 31st. Receiving approval by December 31st will allow your facility to be credited with SRECs as far back as January 1st, 2010.

Due to this time constraint, SRECTrade recommends owners submit applications directly to the DC Public Service Commission. The DC registration process requires an original and notarized application mailed directly to the DC Public Service Commission. Once approved, you can then apply for the EasyREC program.

Instructions for submitting an application to the DC SREC Program:
1. Download and complete the DC RPS Application.

2. Once you have completed the application and had the affidavit of general compliance notarized, mail the original to:

Dorothy Wideman
Commission Secretary
Public Service Commission of the District of Columbia
1333 H Street, N.W
2nd Floor West Tower
Washington, D.C. 20005

Cautionary comment on the DC SREC Market: The DC SREC market is a relatively small market.  Although SRECs are currently selling around $300, the market may soon be over-subscribed. This is due to the significant supply that can be drawn from several states across the region. In addition, DC allows solar thermal facilities to count generation towards the SREC requirement. For these reasons, buyers in the DC SREC market will eventually be able to meet their requirements with ease, which would lead to a potential significant drop in pricing.  The states eligible for the DC market include:

Delaware
Indiana
Illinois
Kentucky
Maryland
New Jersey
New York
North Carolina
Pennsylvania
Tennessee
Virginia
West Virginia
Wisconsin

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CA 33% Renewable Target Onward!

Posted October 20th, 2010 by SRECTrade.

At the end of September, the California Air Resources Board (CARB) voted unanimously to approve a measure that would require entities delivering power to the state to acquire one-third of their power from renewable resources.

This measure is different than the existing 20% target in that it covers both investor-owned utilities and publicly owned utilities. The existing RPS comes under the jurisdiction of the California Public Utilities Commission (CPUC) while the CARB has a more far reaching mandate to regulated GHG emissions under A.B. 32.

Earlier in the month, the state legislature was unable to pass the 33% renewable portfolio standard into law. A spokeswoman for the governor’s office commented that the CARB’s approval carries the same legal weight as a bill passed by the legislature and signed by the governor.

CARB stated that the target is forecast to reduce greenhouse gas emissions by 12-13 million metric tons of carbon dioxide per year by 2020. In addition to the environmental impacts, the CARB and Governor Schwarzenegger expect the measure to incentivize and attract more clean energy project development to California. The California Energy Commission (CEC) recently approved a 392 megawatt solar thermal power plant to be constructed by BrightSource Energy LLC. Other projects are hurrying to receive approvals before the end of the year when federal stimulus incentives expire.

CARB, CPUC, CEC and CA’s independent system operator will all work closely to help implement the new standard. The measure targets a phased approach with 20% by 2012, 24% by 2017, 28% by 2019, and 33% by 2020.

Click here for the full article.

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Senators Introduce Renewable Electricity Standard

Posted October 20th, 2010 by SRECTrade.

At the end of September, Senators Jeff Bingaman, Sam Brownback, Byron Dorgan, Susan Collins, Tom Udall, and Mark Udall introduced a Renewable Electricity Standard (RES). The bill will require electricity generators to acquire specific percentages of electricity supplied to customers from renewable energy sources.

Senator Bingaman commented, “I think that the votes are present in the Senate to pass a renewable electricity standard.  I think that they are present in the House.  I think that we need to get on with figuring out what we can pass and move forward.”

The legislation proposes the following targets to be met from either renewable energy resources or energy efficiency improvements:

YEAR  __                 %

2012-2013…….……..3

2014-2016…….……. 6

2017-2018…….……. 9

2019-2020………… 12

2021-2039………… 15

Eligible renewable energy resources will include wind, solar, ocean, geothermal, biomass, landfill gas, incremental hydropower, hydrokinetic, new hydropower at existing dams and waste-to-energy. Energy providers can comply with the RES by producing renewable energy, implementing energy efficiency measures, purchasing renewable energy or energy efficiency savings, purchasing renewable energy credits or energy efficiency credits, or paying an alternative compliance payment (ACP) at a rate of $21/MWh. The national RES program will not affect state programs.

Click here for the entire press release.

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How To Improve Pennsylvania’s Solar House Bill 2405

Posted September 20th, 2010 by SRECTrade.

Last month Governor Edward Rendell wrote an opinion piece supporting an increase to the existing SREC program in Pennsylvania. The Bill is currently off the table, but will likely resurface later this year.  Though we are hopeful that Pennsylvania steps up its solar goals, this Bill, as written sets a scary precedent: it essentially disqualifies any solar facilities from out-of-state that have been previously approved to generate and sell SRECs in the Pennsylvania market.

There is no doubt that the Solar Renewable Energy Certificate programs in Pennsylvania and other states, such as New Jersey, have been a major catalyst for solar development.  Despite the success of these programs, one key challenge remains prominent in the daily efforts of installers and integrators looking to develop projects: long-term SREC financing. This is particularly the case for larger projects that require lending from banks.  Without a long-term SREC project with an accredited buyer, many of these projects do not get done.  Load-serving entities are the only credit worthy counter-parties in this market since they ultimately need to buy the SRECs to comply with state laws.  The problem is that they only have short-term electricity supply contracts into the state and therefore are loath to enter into long-term SREC contracts for risk of exposure to the liability should their electricity supply contracts not be renewed.

Meanwhile, the only projects getting done on a regular basis are small commercial and residential systems that are finance-able without long-term SREC contracts.  Absent a long-term SREC contract, the key to the success of the solar industry in Pennsylvania and other states with similar programs is the faith that the solar owners and financiers place on the SREC market. It is all too easy for someone to walk away from a solar investment because he or she does not trust the government to stand behind the law that created the market-based SREC program.  This is why when Maryland, Delaware and New Jersey recently updated their SREC laws to increase the requirements and raise the fines, the greatest outcome of these changes was not the quantitative effect but the impact it had on the psyche of the industry. These three states all said loud and clear that the SREC program is here and it is here to stay.

Pennsylvania, in many ways, is doing the same with House Bill 2405 by setting a schedule of fines and increasing requirements. However, there is one piece of the legislation that is a step back for the solar industry in general.  When the original SREC program was created in 2004, the law included SRECs from out-of-state facilities. In a pragmatic move to place an emphasis on the local Pennsylvania solar industry, the new Bill, if passed would exclude out-of-state facilities. This is a perfectly fine change for solar projects moving forward… and it may actually be a good thing for the PA SREC market.

However, as written, the Bill would also exclude out-of-state facilities that have already been financed, built and certified by the Pennsylvania AEPS Program to sell SRECs in the state’s market.  These are solar facilities that have been financed to produce SRECs for the Pennsylvania state market, expecting the payback to come from the proceeds of these sales.  They will be shut out of the Pennsylvania SREC market.

Now if you’re a PA resident or legislator, you may not care since it really does not affect you in any tangible way. Out-of-state facilities increase supply, driving cost down, but excluding them opens up opportunity for local solar projects.  If you’re a PA installer, you will likely be happy just to have it passed as it will be a great thing for the PA solar industry.  However, if you are a solar industry advocate in general and/or someone with a penchant for fairness, you are probably holding your breath alongside the solar owners and installers in Virginia, West Virginia and other states that have been lured to solar by Pennsylvania state law.

It would be a setback to SREC programs everywhere to see the first real example of a change to a state law promoting SRECs that leaves its earlier adopters in the dark. Though we’re hoping for an improved solar legislation in Pennsylvania, we are rooting for legislators to not only do what is good for SREC markets, but also what is just plain right for the people who have made an investment based on the 2004 law. The implementation challenges won’t get any easier if you give the skeptics a reason to doubt the program.

In conclusion, Pennsylvania should most definitely pass HB2405, increasing solar requirements, but it should also grandfather in all facilities that were built on the promise of its predecessor.

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NY SRECs Expected to be Eligible for DC Market

Posted September 16th, 2010 by SRECTrade.

The District of Columbia Public Services Commission has been revising the language of the state RPS, and details are expected to be released at the beginning of October.  Currently, a discrepancy in the wording of the RPS makes the eligibility of PJM-bordering states, such as New York, unclear.  This ambiguity led to the rejection of New York solar facilities earlier this year, and has effectively halted the certification of NY facilities in DC.  We expect that this revision will clarify the status of New York systems, making them eligible for the DC SREC market.  As soon as concrete details are released, SRECTrade will resume registering New York facilities in DC as a part of our EasyREC program.

Although prices in the DC market are close to $300 per SREC, the market is small.  In 2010, a total of approximately 3 megawatts must be installed in order to meet the requirement.  That number grows to 15 megawatts in 5 years.  Considering that facilities in the entire PJM region and adjacent territories are eligible for the DC market, it is quite possible that this market becomes oversubscribed in the future. We foresee the DC market as a viable option for smaller solar facilities for now, but in the long-run, it will be difficult for the solar industry in New York to rely on the DC market. The long-term solution for New York is to pass the Solar Jobs Act that is currently pending in the senate. Hopefully it will pass this fall and create one of the largest SREC markets in the nation.

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