Archive for the ‘Cross-Listing’ Category

Distributed Generation Amendment Act of 2011 Implemented

Posted September 27th, 2011 by SRECTrade.

The Council of the District of Columbia and the city’s Mayor signed into law the Distributed Generation Amendment Act of 2011. SRECTrade closely watched this legislation as it evolved over the last 7 months. Our most recent blog on the subject is here. The Act ultimately focuses on providing a sustainable SREC market for the residents of Washington DC while containing the potential cost to ratepayers. The amendment increases the RPS solar requirements and closes the District’s boarders from out-of-district sited systems. The affect on the market is demonstrated in our Capacity Update of systems eligible to create DC SRECs moving forward.

This week, the PJM tracking registry (PJM GATS) is undergoing the process of de-certifying systems that were once eligible under the previous Washington DC RPS law. As per the new legislation, all non-Washington DC sited systems that were approved after January 31, 2011 by the DC Public Service Commission are no longer eligible to sell SRECs in the DC market. This cutoff date is clearly displayed by a customer’s DC State Certification Number; any certification number beginning “DC-10…-SUN-I” was certified before January 31, 2011, while any certification number beginning “DC-11….-SUN-I” was certified after that date.

What does this mean for the market?

While this law is not likely to cause DC SREC prices to rebound immediately to the level that was seen in 2010 (due to the fact that buyers have likely accumulated extra SRECs throughout the early part of this year, along with any forward contracts that were in place before the law was implemented), this law is an important step to alleviating the oversupply that has depressed DC SREC prices.

What does this mean for facilities certified after January 31, 2011?

Any facility not located within Washington DC with the state certification number beginning “DC-11…” has had their certification number de-activated. The facility is no longer eligible to generate future SRECs in the DC market, and any SRECs they have already created have lost their eligibility for the DC SREC market.

– If your facility falls under this category, and is already eligible to sell SRECs in another state, you will not see any disruption in your account except that you are no longer eligible for the DC market.

– If your facility is eligible to be certified for another SREC market, but you were only certified in DC, you can apply for certification in another state market. Please see this chart for more information on your eligibility.

– If your facility was originally only eligible for DC (i.e. your system is located in WI, NY, NC(non-Dominion Power territory) or you had a Solar Thermal system not located within Washington DC), PJM GATS will be listing your facility as “inactive”. Any SRECs you have created will not be eligible for sale, and you will not create future SRECs unless another market opens that allows your facility to be certified. Currently, solar facilities in this scenario are only eligible in the NC SREC market – but due to extremely low pricing in the oversaturated NC market, this option is not very viable for solar owners.

SRECTrade will continue to post opportunities for cross-listing SRECs in other state markets.

Maryland and out-of-state SRECs

Posted January 14th, 2011 by SRECTrade.

The recognition of out-of-state SRECs in Maryland has been a fairly ambiguous topic for quite some time now. According to the RPS solar carve-out law in Maryland, statute §7–701:

(i)“Renewable energy credit” or “credit” means a credit equal to the generation attributes of 1 megawatt–hour of electricity that is derived from a Tier 1 renewable source or a Tier 2 renewable source that is located:

(1)   in the PJM region; or

(2)   outside the area described in item (1) of this subsection but in a control area that is adjacent to the PJM region, if the electricity is delivered into the PJM region.

This means that Maryland buyers can procure SRECs from anywhere in the PJM region or a “control area” bordering the region if the electricity is delivered into the region.

Later, the law gets even trickier in §7–704 to say:

“On or before December 31, 2011, energy from a Tier 1 renewable source under § 7–701(l)(1) of this subtitle that is not connected with the electric distribution grid serving Maryland is eligible for inclusion in meeting the renewable energy portfolio standard only if offers for solar credits from Maryland grid sources are not made to the electricity supplier that would satisfy requirements under the standard and only to the extent that such offers are not made.”

Note that § 7–701(l)(1) refers to solar specifically. This makes things even more confusing because what it attempts to say is that Maryland buyers can purchase SRECs from facilities not connected to the grid serving Maryland until the end of 2011 as long as they can prove they cannot source SRECs from within the grid serving Maryland.

What does that even mean? Is the “electric distribution grid serving Maryland” the same as the PJM Region? Is it just the state of Maryland? Is it the PJM Region plus adjacent control areas as long as the electricity is delivered into the PJM Region? Furthermore, how does a buyer prove that they can’t fulfill their requirements within the electric distribution grid, so that they can get approval to buy from facilities not connected to the grid?

Our interpretation: If you’re not connected to the electricity grid serving Maryland, it’s probably not worth the trouble to apply. For starters, if you can sell them, your SRECs are only usable in 2011. In addition, the buyer would need to provide proof that they can’t procure SRECs from within the grid serving Maryland. Assuming that this refers to the PJM Region, then it is highly unlikely that buyers in Maryland would not be able to procure SRECs from within the grid. And finally, onerous requirements like “Mail the original and 14 paper copies of all documents” in the Maryland application process make it one of the most tedious state certifications out there.

What we do know is that there are 2.3 MW of projects outside Maryland that are currently registered in the state and generating SRECs in GATS. These facilities are from: DC, DE, IL, NC, NY, OH, PA, VA, WV.  Of the 107 facilities from outside Maryland, 63 were built in 2010. All of these states are within the PJM Region with the exception of NY, which had 4 facilities from 2004-06 approved. It is likely that the Maryland Public Service Commission has since stopped accepting NY facilities and other facilities from outside the PJM Region.

While we can’t predict how buyers view out-of-state SRECs in Maryland, we now have an in-state/out-of-state option for buyers in the Maryland SREC auction. If you have a facility that is located in the PJM region, we would encourage you to apply to the Maryland SREC market (despite the impact that 14 copy requirement might have on the environment). Instructions can be found on our State Certifications page. We can also do it for a fee if you are an EasyREC customer.

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Importing and Exporting SRECs across Registries

Posted July 21st, 2010 by SRECTrade.

With the launch of the North Carolina Renewable Energy Tracking System (NC-RETS), North Carolina is paving the way for what could be the future for SREC markets. For the first time, an SREC created in one region’s registry will be transferable to a buyer in another region’s registry. This cooperation amongst registries could be the first step towards a permeable nationwide SREC market.

North Carolina is currently working with other renewable energy certificate tracking systems to approve a process for importing and exporting SRECs. The approval of exporting SRECs from other tracking systems and importing them into NC-RETS would allow solar system owners located in states without viable SREC markets to sell into the North Carolina SREC market. This is all possible because almost all of the registries were built with similar technology developed by APX.  More information on all of the registries can be found here: APX Primer on REC Registries.

NC-RETS is working with the parties responsible for maintaining the other regional registries to develop the importing and exporting process.  Here is a list of those registries and an update on the status of importing and exporting:

NARR: The North American Renewables Registry (NARR) was developed by APX to serve the needs of states and regions that have not implemented a REC tracking system.  This covers most of the Southeastern U.S., Alaska and Hawaii.  NARR has already established importing/exporting procedures with NC-RETS.

MRETS: The Midwest Renewable Energy Tracking System (M-RETS), the registry that tracks the generation of SRECs in 8 Midwest U.S. states and the Canadian province of Manitoba, has approved the exportation of SRECs and is implementing the necessary software upgrades.

GATS: Generation Attribute Tracking System covers the Mid-Atlantic states and currently tracks the majority of SREC volume due to member states like New Jersey, Pennsylvania and Maryland.  GATS is expected to allow importing/exporting soon.

WREGIS: The Western Renewable Energy Generation Information System (WREGIS), the registry that tracks the generation of SRECs in 14 Western U.S. states, Baja California, and the Canadian provinces of Alberta and British Columbia, is capable of managing exports and is in the process of making a policy decision to allow the system to export SRECs.

ERCOT: Texas, the sixth state to adopt an RPS in 1999, was the first to implement a procedure for meeting the RPS.  The Electric Reliability Council of Texas (ERCOT) was the first registry of its kind.  Unfortunately, it does not currently have the capability to export SRECs and it may require legislative approval to make the necessary changes to the system’s software. However, NC-RETS and APX are working with ERCOT to come up with a solution.

PJM Region

Posted March 28th, 2010 by SRECTrade.

The PJM Interconnection is a regional transmission organization.  It serves to connect the electricity produced by the various utilities across a region.  In several states, the Renewable Portfolio Standard legislation lets utilities count renewable electricity produced within the PJM region towards meeting the state’s renewable goals.

In Pennsylvania, for example, a resident within the PJM region can apply for certification in the Pennsylvania SREC program.  If your system is convered in this map, you can sell SRECs to PA!

Washington, DC is similar to Pennsylvania in that both allow SRECs from anywhere within the PJM region, however DC will also qualify facilities that are eligible to deliver their electricity into the region. This may include facilities in states that are adjacent to the PJM region such as New York or Wisconsin.

Ohio is another state that allows SRECs from out of state. In that specific case, the utilities are limited to buying 50% from out of state and only from states within the region that are contiguous: Pennsylvania, West Virginia, Kentucky, Michigan and Indiana.

Washington, DC is similar to Pennsylvania in that both allow SRECs from anywhere within the PJM region, however DC will also qualify facilities that are eligible to deliver their electricity into the region.

For these reasons, it is important to know what constitutes the PJM region to determine whether or not you qualify.  Here is a map of the region, along with the retail electricity companies who are served by PJM.

pjm-region


State SREC Markets

Posted January 28th, 2010 by SRECTrade.

The following map shows all the SREC markets in the U.S. along with the states that have a solar requirement as part of the state renewable porfolio standard (RPS).  There are three conditions that must be present in order for a state to implement an effective SREC market:

  1. RPS Solar Carve-Out: The RPS solar requirement distinguishes solar from other renewable energy resources and in most cases will value solar electricity at a higher rate than other renewables. Most states will set a target for solar, either as a percentage of the total electricity sold into the state, as a fixed capacity target in megawatts (MW) or as a solar energy target measured in megawatt hours (MWh) or SRECs produced in a year.
  2. Unbundled, Tradeable RECs: A state must allow the SRECs to be owned and traded by the generating facility. In some states, your utility company owns your SRECs. This is a common stipulation in state solar grant or rebate programs. Other states have a budget for solar. For example, California is currently not a viable SREC market because the state requires that utilities purchase the SRECs bundled with the electricity that the system produces. The SRECs cannot be unbundled and sold separately.
  3. Penalty for Non-Compliance: Finally, in order to have a robust SREC market, your state must implement some sort of fine or penalty for non-compliance. This is commonly known as a solar alternative compliance payment (SACP). The SACP is what drives the values of SRECs above any other type of REC. Without the SACP, it is difficult to incentivize buyers to pay prices that promote solar growth.

The states with robust SREC markets have the three criteria of a solar requirement, SREC ownership and the SACP. This map shows all the states that have solar requirements and those that specifically have SREC markets. In addition, we’ve added states that don’t necessarily have their own solar requirements, but are eligible to sell into the SREC markets of other states. The states that they are eligible for are listed in the map under each state.


Cross Listing Your SRECs

Posted January 3rd, 2010 by SRECTrade.

2011 Update: State certification information can be found here

One of the benefits of the SRECTrade multi-state auction platform is the ability to cross-list in multiple states in which you have registered your SRECs. If an SREC is cross-listed, it will be included in any state in which it has been registered to be sold.  SRECs will be sold in the state auction that offers the most value. In order to qualify to sell your SRECs in a state that accepts out-of-state SRECs, you need to get your system certified in that state. The following section has information on what states accept out-of-state SRECs and how to get your systems registered and obtain a state certification number. For EasyREC customers, SRECTrade can help you register in the states available to you.

SREC Markets by State

SREC State Registration Information:

Delaware

To get a Delaware state certification number, your installation must be located in DE. You must apply to become an Eligible Energy Resource. The link for the application is here.  For more information, go to the Delaware Public Service Commission.

Contact:
Delaware Public Service Commission
861 Silver Lake Boulevard
Cannon Building, Suite 100
Dover, DE 19904
Main: (302) 736-7500
Toll-Free: (800) 282-8574
Fax: (302) 739-4849

District of Columbia

Eligible to states within and adjacent to the PJM Region. For information on the DC registration process, see DC State Certification Instructions.

Contact:
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

Maryland

To register in Maryland, your solar installation must be in MD and you must complete and file an application for certification as a Solar Renewable Energy Facility (REF) with the Public Service Commission. The link to the application is here.  For more complete details on the process, see Maryland SREC Registration Details.

New Jersey

New Jersey is a closed market, therefore only SRECs produced in New Jersey are eligible. New Jersey residents can apply for state certification at the New Jersey Office of Clean Energy’s website.

Contact:
New Jersey’s Clean Energy Program
c/o Conservation Services Group
75 Lincoln Highway, Suite 100
Iselin, New Jersey 08830
Phone: 866-NJSMART (866-657-6278)

North Carolina

North Carolina is still in the early stages of implementing an SREC program. The state is still accepting applications for a REC tracking system through December 15, 2009.  More information can be found on the North Carolina Utilities Commission website. A sample application can be found here.

Contact:
Chief Clerk
North Carolina Utilities Commission
4325 Mail Services Center
Raleigh, NC 27699-4325

Ohio

Utilities in Ohio are allowed to procure 50% of the SRECs from out of state facilities. However, these states must be contiguous with Ohio (PA, MI, IN, KY, WV). Instructions and forms required for Ohio certification can be found here: Application for Certification as an Ohio Renewable Energy Resource Generating Facility

Contact:
Public Utilities Commission of Ohio
Email: AEPS@puc.state.oh.us
Toll-Free: (800) 686-PUCO (7826)
Phone: (614) 466-3292 (in Columbus area)
Fax: (614) 752-8351
180 East Broad Street
Columbus, Ohio 43215
Directions to the PUCO

Pennsylvania

Utilities in Pennsylvania are allowed to buy out of state SRECs from solar generators in the PJM region to meet the Renewable Portfolio Standard. If you are interested in selling in PA, you need to get your solar system registered.  For a detailed explanation of the process with screenshots see our most recent post on Pennsylvania State Certification Registration Process.

Contact Info:
Dina M. Deana
Pennsylvania AEPS Program Manager
Clean Power Markets, Inc.
Phone: 1-877-AEPS-773 (1-877-237-7773)
Fax: (610) 444-9213
Email: paaeps@cleanpowermarkets.com



Qualifying for the Ohio SREC market

Posted December 16th, 2009 by SRECTrade.

This is the first year that the Ohio RPS has come into effect and we expect Ohio to be one of the best market for SRECs over the next few years.  With an established SACP starting at $450 this year, a large electricity market, and a growing solar requirement, we expect Ohio to surpass Pennsylvania and many of the other SREC states in volume.  For that reason, we recommend registering in Ohio if you are from Ohio and any of its neighboring states: Pennsylvania, West Virginia, Kentucky, Indiana and Michigan.  For Pennsylvania residents, the early months of the Pennsylvania auctions brought a price of $290-$300, but your PA SRECs could be worth up to 30% more in the Ohio market.  To find out more about the Ohio SREC program follow this link.

Registering in Ohio

Utilities in Ohio are allowed to procure 50% of the SRECs from out of state facilities. However, these states must be contiguous with Ohio (PA, MI, IN, KY, WV). Instructions and forms required for Ohio certification can be found here: Application for Certification as an Ohio Renewable Energy Resource Generating Facility

Contact:
Public Utilities Commission of Ohio
Email: AEPS@puc.state.oh.us
Toll-Free: (800) 686-PUCO (7826)
Phone: (614) 466-3292 (in Columbus area)
Fax: (614) 752-8351
180 East Broad Street
Columbus, Ohio 43215
Directions to the PUCO

PA SRECs begin accruing at time of application for new facilities

Posted November 9th, 2009 by SRECTrade.

If PA is the first state you are registering SRECs in, then you will want to apply for PA certification as soon as possible… Unlike some other states, the Pennsylvania SREC program (also known as AEP Program) will not count SRECs generated at the time of installation or interconnection. SRECs will only be credited from the time of application to the PA program. However, if your system has already been registered in another state, any SRECs that are generated in that state will have the PA certification applied to them, so this will not apply to your SRECs. The PA AEPS  now requests a meter reading at the time of application so that it can use that reading as the starting point of your SREC generation.

To apply to the PA program as an EasyREC customer, please complete the PA SREC certification forms.  All other users can refer to our guide on applying for PA certification here.

DC SREC State Certification Instructions

Posted November 4th, 2009 by SRECTrade.

For EasyREC customers:
If you have signed up for the EasyREC service, we will do the DC State Certification on your behalf.  Please complete our EasyREC registration forms to get started. Please fax the forms to SRECTrade at (732) 453-0065.

To learn more about EasyREC go to: www.srectrade.com/easyrec.php

Eligibility for SREC certification in DC:
DC allows systems from states in the PJM region and those that are adjacent to the region and capable of supplying electricity into the region. Solar systems in the following states have been approved for the DC SREC market (find out more here):

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

Registration Process for NON-EasyREC customers:
The DC registration process requires an original and notarized application mailed directly to the DC Public Service Commission.  If you would like to register your system in DC, please follow these guidelines to complete the appropriate forms:

For Non-EasyREC customers:
If you currently have a facility certified in another state (ie. MD, DE, NJ, or PA), download and complete this form.
If you do not have a facility certified in another state (ie. DC, VA, WV, TN, NC, KY) use this form.

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

The DC registration process is currently taking approximately 10-12 weeks to complete.  Once approved, Washington DC will mail a letter to you with your facilities state certification number.


PA Certification now available via EasyREC

Posted November 4th, 2009 by SRECTrade.

Anyone within the PJM region can be certified in Pennsylvania.  If this is the first state you are getting certified in, the PUC has instructed the program manager to only count SRECs generated after the date of application.  Therefore, it is imperative that you apply as soon as possible.  If you have previously been certified in another state, your SRECs will all have the PA certification applied to them when you are approved. If you are an EasyREC customer already, simply fill out the PA State Certification Forms. If you have not signed up for EasyREC, you will also need to complete the EasyREC forms.  Please feel free to contact us at EasyREC@srectrade.com.