SRECTrade will host a webinar covering the Maryland and Washington, DC SREC markets on Thursday, 3/28 at 3 pm ET. As with previous state market focused webinars, SRECTrade will cover MD and DC specific market trends and capacity projections. Additionally, we will address options clients have for selling SRECs through SRECTrade.
Register here: https://srectrade.clickwebinar.com/MD_and_DC_SREC_Market_Webinar
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On January 8, 2013 B20-0057 , the “Community Renewable Energy Act of 2013” was introduced. The bill has 8 sponsors (Alexander, Barry, Bonds, Cheh, Graham, Grosso, McDuffie, and Wells), a majority of the 13-member DC Council. The “Community Renewable Energy Act of 2013” proposes to amend the “Retail Electric Competition and Consumer Protection Act of 1999” (which created net metering in Washington, DC) to allow rate payers in DC to “subscribe” to electricity from solar power produced from registered “Community Energy Generating Facilities.” If passed, this bill would open up the solar electricity market in DC to the entire rate payer base (including renters and condo owners) and not just property owners. Theoretically, legislation of this nature would also lower the investment risk of going solar in the District for “subscribers” and project developers by diversifying the required type and commitment of investors able to participate.
The bill must next progress to committee before it can be voted on by the general council. SRECTrade will track the progress of the legislation and provide updates as applicable. View the proposed bill here.
Some interesting clauses to note in the proposed bill:
– “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.
– Most interestingly, the proposed bill requires that the District Department of Energy and the District Sustainable Energy Utility to develop a proposal within 6 months of the bill’s passage for an equitable and creative program for financing community net metering projects.
TweetIt’s been a while since we last updated our readers on the fundamentals of SRECs for solar hot water (SHW) systems. Currently two markets, Washington DC and Maryland, allow for SRECs sold from solar hot water systems. There have been proposals to create SREC markets for SHW in other markets, but no other states have concrete plans to do so.
Key concepts:
SRECs from SHW systems are calculated by using the annual energy estimate provided by the Solar Rating and Certification Corporation (SRCC) OG- 300 Water Heating System Rating or by converting BTUs to kW-hr equivalents from BTU meters. BTU meter readings are provided directly to the tracking registry (PJM GATS) in BTU’s and PJM GATS converts the BTUs into kilowatts. Calculate kW-hr equivalents by multiplying system BTUs by .000293 and 1,000 kW-hrs = 1 SREC.
Maryland SHW Registration Rules
District of Columbia SHW Registration Rules
If you’d like to utilize SRECTrade to monetize SRECs produced from SHW systems in either MD of DC please fill out this application and follow the directions on the form.
TweetThe 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.
TweetThe Council of the District of Columbia unanimously voted, today July 12th, to close the DC SREC market to out-of-state systems. The Distributed Generation Amendment Act of 2011 (Bill 19-10) increases the SREC requirement in 2011 as well as establishes an SACP schedule through 2023. Once in effect, the bill will allow out-of-state systems registered prior to 1/31/2011 to continue to sell SRECs in the DC market. The DC Public Services Commission has not provided clarification on how the bill will affect out of state systems that have already granted DC registrations after the January 31st 2011 grandfather date. For more information on the bill please refer to our previous blog postings here and here.
The bill is not yet law. It first must go through a 30-day Congressional Review process before it can go in to effect. Given these mechanistic delays we don’t expect the bill to go in to effect for at least another month.
The following chart illustrates which out-of-state systems will be effected by the legislation.
| State | Eligible Markets (after B19-10 is effective) |
| DE | DE, PA |
| IN | OH; PA (if in American Electric Power territory) |
| IL | PA (if in Com Ed territory) |
| KY | OH; PA (if in American Electric Power territory) |
| MD | MD; PA |
| MI | OH; PA (if in American Electric Power territory) |
| NC | NC; PA (if in Dominion Electric Territory) |
| NJ | NJ, PA |
| NY | – |
| OH | OH; PA |
| PA | PA; OH |
| TN | PA (if in American Electric Power territory) |
| VA | PA |
| WV | OH; PA |
| WI | – |
On June 7, 2011, the Council of the District of Columbia read and reviewed the latest draft of Bill 19-10, also known as the Distributed Generation Amendment Act of 2011. For the details of the pending amendment please click here. The amendment received a substantial support from the local legislators as well as the DC solar community. The final vote after the first reading was 14-0, unanimously in favor of putting the amendment into effect.
As it currently stands, below are the key points of the amendment under consideration:
– Solar thermal system eligibility to participate in the SREC market. For more info see this post.
– Implementation of new solar capacity requirements and a new solar alternative compliance payment (SACP) schedule:
| Year | Current RPS Solar Requirement | Proposed RPS Solar Requirement Jan-11 | Proposed RPS Solar Requirement June-11 | Current SACP | Proposed SACP June-11 |
| 2011 | 0.04% | 0.25% | 0.40% | $500 | $500 |
| 2012 | 0.07% | 0.50% | 0.50% | $500 | $500 |
| 2013 | 0.10% | 0.75% | 0.50% | $500 | $500 |
| 2014 | 0.13% | 1.00% | 0.60% | $500 | $500 |
| 2015 | 0.17% | 1.25% | 0.70% | $500 | $500 |
| 2016 | 0.21% | 1.50% | 0.825% | $500 | $500 |
| 2017 | 0.25% | 1.75% | 0.98% | $500 | $350 |
| 2018 | 0.30% | 2.00% | 1.15% | $500 | $300 |
| 2019 | 0.35% | 2.25% | 1.35% | $500 | $200 |
| 2020 | 0.40% | 2.50% | 1.58% | $500 | $200 |
| 2021 | — | — | 1.85% | — | $150 |
| 2022 | — | — | 2.175% | — | $150 |
| 2023 | — | — | 2.50% | — | $50 |
The amendment puts it place a system size cap, stating that all solar requirements be met by acquiring SRECs from systems no larger than 5 MW. Additionally, the amendment requires systems to be sited within the District. For systems located outside of the District, the amendment plans to grandfather systems smaller than 5 MW in capacity that were registered as a renewable resource with the District prior to January 31, 2011.
As mentioned in our previous blog post on this potential change to the District’s existing RPS law, this bill will take very important, concrete steps to addressing the current oversupply in the DC market.
It is still unclear how the grandfather date of 1/31/2011 will affect facilities outside the district that have been registered by the DC Public Services Commission and issued SRECs since then.
As the District is still operating under the current RPS law, out-of-state systems are still eligible to be certified for SREC generation, but it is unknown if the registration will hold value considering the implications of the amendment. The DC Council website does not currently indicate the next date for further consideration, but SRECTrade will continue to provide additional information as it becomes available.
TweetRecent legislation passed by the council of the District of Columbia now allows non-residential solar thermal systems to be registered to produce DC SRECs. Under the new legislation non-residential systems must be SRCC OG-100 certified. The legislation went into effect on March 12, 2011 and will expire on October 23, 2011. Previously the District only accepted SRECs from residential SRCC OG-300 certified solar thermal systems.
The new legislation has the following requirements for solar thermal systems:
Solar thermal non-residential systems producing or displacing more than 10,000 kW-hrs per year must be SRCC OG-100 certified and the annual energy output must be determined by an onsite OIML compliant meter.
Solar thermal non-residential systems producing or displacing 10,000 kW-hrs or less per year must be SRCC OG-100 certified and their annual energy output can be determined by the SRCC OG-300 performance rating protocol OR by an onsite OIML compliant meter.
Residential SRCC OG-300 certified solar thermal systems are not affected by this legislation and can continue to be registered in DC.
Given the current supply dynamics of the DC SREC market, this legislation will continue to provide more supply to the oversubscribed program. While SREC prices could continue to decline in the near term, it may be beneficial for solar thermal system owners, previously not eligible for the DC market, to register and receive certification as an option for potential SREC liquidity.
For an update on the current capacity certified to produce DC SRECs see the SRECTrade SREC Markets Report: March 2011.
Additionally, the Distributed Generation Amendment Act of 2011, could have a positive impact on the oversupplied DC SREC market. The legislation is still pending and details associated with the cut off date for grandfathering in out of state DC registered systems are still unknown. SRECTrade will continue to monitor this piece of legislation and provide additional information as it becomes available. For more background on the proposed amendment see these blog posts:
Could Change Be Coming to Washington DC’s SREC Market?
DC Bill Introduced to Limit Out-of-State Facilities
For information on registering a solar thermal system directly with DC Public Services Commission see this page, or consider registering through SRECTrade’s EasyREC service.
As you can see from our monthly update on the capacity registered in the SREC states, the DC market has requirements of no more than 8 MW of installations over the next two years. Today, there are over 27 MW currently generating SRECs that are eligible for the DC SREC market. Only 1.1 MW of the 27 MW are actually located within the District. This oversupply and weight towards foreign facilities is likely what prompted the potential legislative changes to the DC SREC market that we highlighted earlier.
This Bill is still in the early stages of the legislative process and it is unknown how long it would be before it is passed. However, it will take several months, at a minimum, before it would go into effect. At this point, it has been referred to the Committee on Public Services and Consumer Affairs, chaired by Councilmember Yvette Alexander who will establish the timing of hearings and markups of legislation.
After the hearing, it will likely go through an iterative process that will take several weeks before it is ready for a vote and another 2-4 weeks before a 2nd and final vote to enact the Bill before it is sent to the Mayor to sign. Once signed by the Mayor, the District must then send it to Congress for a lengthy review period.
The Bill seems to have enough support within the Council to have a good chance of being passed. Which then begs the question, how will they approach the grandfathering of out-of-state facilities that are already registered in DC. There are two important details here. First is the cutoff date. The initial date listed on the proposed Bill was January 31, 2011, however it is likely that if it takes several months to a year to enact the law, the actual cutoff date will be adjusted accordingly. The second detail is what defines “registered”. Would it mean any facility that was built prior to the cutoff date? Or is it any facility that has submitted an application to DC prior to the cutoff date? Or is it any facility that is approved prior to the cutoff date? The problem with the third approach is that the date an application is submitted is within the control of the solar owner, but the date that it is actually certified is not. We think it would be consistent with existing policies that DC would interpret “registered” as the date by which an application is submitted to DC.
SRECTrade will continue to follow the progress of this legislation. Any stakeholders interested in submitting testimony can do so by contacting the office of Councilmember Alexander.
TweetWashington, DC Councilmember Mary M. Cheh has introduced a Bill to amend the solar carve-out in the District. It is called the Distributed Generation Amendment Act of 2011. The announcement can be found here. Among the changes, the most notable will restrict the DC SREC market to facilities located in the District, starting in 2012. The Bill will grandfather any facilities registered in DC prior to January 31, 2011. In addition to this notable change, the requirements in each year will increase significantly through 2020 and the SACP will be extended until 2020. Here are the key details:
1. Facilities sited outside D.C. will remain eligible as long as they were registered with the D.C. Public Service Commission prior to January 31, 2011.
2. Starting in 2011, solar requirements will increase as follows:
| Year | Old RPS Solar Requirement | New RPS Solar Requirement | SACP |
| 2011 | 0.04% | 0.25% | $500 |
| 2012 | 0.07% | 0.50% | $500 |
| 2013 | 0.10% | 0.75% | $500 |
| 2014 | 0.13% | 1.00% | $500 |
| 2015 | 0.17% | 1.25% | $500 |
| 2016 | 0.21% | 1.50% | $500 |
| 2017 | 0.25% | 1.75% | $500 |
| 2018 | 0.30% | 2.00% | $500 |
| 2019 | 0.35% | 2.25% | $500 |
| 2020 | 0.40% | 2.50% | $500 |
This is good news for what has been an oversubscribed D.C. SREC market, though it will have a negative impact on facilities across the region that will not be registered by January 31, 2011. Facilities that are registered and included after any changes are made will benefit from inclusion in the D.C. SREC market which should see a rebound in pricing. Unlike the unsuccessful efforts of Pennsylvania earlier this year to exclude out-of-state facilities, this effort by D.C. has been done with the consideration of the solar owners that have committed to solar on account of the opportunity to sell SRECs in D.C. Regardless of the merits of a move to a closed SREC market, the inclusion of previously registered facilities is a crucial aspect of any changes that are made.
Note: It is still too early to tell if this Bill will pass. It is highly unlikely that it would be passed before January 31. Therefore it is unclear what the deadline will be if/when such a bill were to pass. Anyone considering submitting an application to the D.C. market that should file one directly with the D.C. Public Service Commission. Instructions can be found on our State Certifications page.
TweetThe 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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