The opt-in term for MA systems will likely be reset to 8 years for systems that submit their information to the DOER after June 20th. SRECTrade customers should submit the complete system information for any new systems prior to June 1st to ensure that SRECTrade can process them and correct any errors prior to the June 20th deadline. Existing systems which are already qualified or have submitted their complete information will not be subject to any change in their opt-in term and do not need to take any action at this time.
There have been a number of questions recently submitted by astute readers of the MA solar carve-out rules about the potential for reduction in the opt-in term. One of the features of the MA solar carve-out is a dynamic opt-in term that expands and contracts based on the over or under supply of SRECs each year. The opt-in term is the length of time that a generation unit is eligible to participate in the Solar Credit Clearinghouse Auction, typically referred to as the last chance auction, run by the MA Department of Energy Resources. The opt-in term was originally set to 40 quarters (10 years), and is increased or decreased by four quarters for each full 10% of the compliance obligation that is deposited into the last chance auction. However, it can only change by a maximum of 8 quarters per year, and can never go below 5 years or above 10 years. This system is designed to make solar installation less attractive in an over-build and more attractive in an under-build scenario, hopefully avoiding the significant volatility seen in other state SREC markets.
Each system is assigned an opt-in term at the time it receives its statement of qualification. The term commences the earlier of the RPS Effective date (the date a system is turned on or receives interconnection, whichever is later) or the first day of the next calendar quarter from the date of qualification. Once a system is assigned an opt-in term, it keeps that term for the life of the system. Any changes to the opt-in term only impact new systems going forward.
The opt-in term has remained at 10 years because no SRECs were deposited in the last chance auction last year. However, based on the installed base of systems in MA in 2012, SRECTrade calculates that approximately 50,000 more SRECs were produced than the 73,400 needed under the RPS. This will trigger a maximum 8 quarter reduction in the opt-in term. Systems can receive qualification prior to interconnection if a completed application is submitted to the DOER by June 20th. Submitting an application to the DOER prior to June 20th will allow the system to receive the current 10 year opt-in term. The applications will need to include all system information, however the system information can be updated with the final build specs when the interconnection letter is submitted. We recommend that all SRECTrade customers have their full application in to SRECTrade by June 1st, to allow us to check for any missing information and ensure the completed application is submitted by the June 20th deadline.
For more information on the Massachusetts 10 year opt-in deadline please visit the Massachusetts Department of Energy Resources Statement of Qualification page.
Update, 2/25/2013, per an email from the DOER, systems greater than 1 MW must prove that they have received all applicable state and local permits (if they have not yet received interconnection) in order to qualify for the 10 year opt-in prior to June 20th.