Archive for the ‘Massachusetts’ Category

Massachusetts DOER Releases Straw Proposal on Clean Peak Standard (CPS) Program

Posted April 15th, 2019 by SRECTrade.

On April 2nd, the Massachusetts Department of Energy Resources (DOER) held a stakeholder meeting in which they presented their straw proposal on the new Clean Peak Standard (CPS) Program. As per the DOER, the program’s primary objective is to “implement a clean peak program that aligns clean energy generation and zero emission demand resources with periods of peak electricity demand in the most cost-effective manner for Massachusetts customers possible while reducing emissions.” To effectively achieve this goal, the program intends to couple the co-deployment of energy storage and renewable resources with demand response resources to help flatten the electric load curve and reduce overall emissions from the electricity sector.

The proposal lays out four separate eligible CPS resources:

  1. New RPS Class I resources in operation on or after January 1, 2019
  2. Existing RPS Class I/II resources (in operation prior to January 1, 2019) that are paired with an energy storage system
  3. Standalone energy storage systems
  4. Demand response resources

Eligible resources would be able to generate Clean Peak Certificates (CPCs) during predefined Seasonal Peak Periods. Each season would have a defined, 4 hour daily peak period in which CPCs could be generated. CPCs would be minted on top of any other Renewable Energy Credit (REC) that the asset produces.

The DOER did not provide details on key program metrics and guidelines in their proposal including price support mechanisms, metering requirements, and tracking and verification process. These parameters will be established once the DOER’s contracted consultants provide further analysis support. The DOER requested that stakeholders submit comments on the proposal by April 12th and they plan to release a draft regulation by the end of Q2 2019.

Massachusetts DOER Files Alternative Portfolio Standard (APS) Emergency Rulemaking

Posted April 9th, 2019 by SRECTrade.

On April 5th, the Massachusetts Department of Energy Resources (DOER) filed emergency regulations that amend portions of the current version of 225 CMR 16: Alternative Energy Portfolio Standard (“APS”).

Specifically, the emergency regulation cancels the transition from pre-minting to forward minting for all small (residential) renewable thermal technologies. As such, small systems will continue to receive their credits upfront, in lump-sum. These proposed changes will take effect immediately and remain in effect for three months. If the DOER successfully concludes the entire rulemaking process within the next three months, the emergency amendments will become law.

SRECTrade provides comprehensive management and transaction services for renewable thermal asset owners within the APS program. Please reach out to SRECTrade if you believe you are eligible or have any questions regarding the program.

Massachusetts SREC-I and SREC-II Update

Posted January 15th, 2019 by SRECTrade.

With Q3 2018 issuance numbers out, SRECTrade would like to provide an update on the current standing of the SREC-I and SREC-II markets.

SREC-I 

The SREC-I market is not subject to any new capacity and, as such, is largely impacted by electricity load figures and solar production. Given the current Massachusetts Department of Energy Resources (MA DOER) estimates for exempt load, expected increased retail electric load*, and SRECTrade’s projections for final 2018 SREC generation figures, the 2018 SREC-I market will be undersupplied by approximately 91,000 SRECs, or 10.9% of the exempt load adjusted obligation. Currently, SRECTrade projects the 2019 SREC-I market will have a similar dynamic of undersupply, with a shortage of approximately 46,000 SRECs, or 5.8% of the estimated exempt load adjusted obligation. For specific details, please see our full presentation here.

The market seems to have taken this undersupply into account, with 2018 and 2019 SREC-Is bid at approximately $400 and $370, respectively. These values amount to approximately 94% and 91% of their respective ACP levels ($426 and $404, respectively).

SREC-II

The SREC-II market closed to new capacity as of November 26, 2018. While systems under 25 kW DC must have been interconnected prior to the closing date, applications will still be accepted through February 15, 2019. As such, there is still some uncertainty as to how much additional residential capacity will apply into the program prior to February 15th, although it can be reasonably assumed that this capacity will be marginal. In addition, there exists approximately 80 MW of market factor-adjusted commercial (>25 kW DC) capacity that has received indefinite extensions for the SREC-II program. These systems are mechanically complete and will begin their SREC production once they receive Permission to Operate (PTO) from their respective utility. We assume in our analysis that 90% of these systems will receive PTO within a year of the closure of SREC-II (November 26th) in equal monthly increments, and the remaining 10% will receive PTO after 12 months. This puts our projected final market factor-adjusted SREC-II capacity at 1,534 MW.

Using these assumptions, as well as DOER’s estimates for exempt load, electric load projections, and SRECTrade’s SREC generation forecast, the 2018 SREC-II market will be undersupplied by approximately 145,500 SRECs, or 8.3% of the exempt load adjusted obligation. As it stands, SRECTrade projects the 2019 SREC-II market will be more balanced with a slight oversupply of 7,600 SRECs, or 0.4% of the exempt load adjusted obligation.

The markets have seemingly digested the fact that the 2018 SREC-II market will be undersupplied, bid at approximately $325 or 93% of the ACP ($350). The 2019 SREC-II market has trended upwards in tandem with the 2018 market, however remains split between the SCCA price ($244) and ACP ($333), currently bid at approximately $290. This reflects our projection of a balanced dynamic in 2019.

Should you have any questions about the enclosed analysis or need transaction and management services, please contact us.

*See 2016 MA DOER RPS and APS Annual Compliance Report page 21 for historic and projected retail electric load figures. 

MA SREC-II Application Deadlines and MA SMART Program Application Opens

Posted November 26th, 2018 by SRECTrade.

November 30, 2018 Update: Due to this email from the Massachusetts Department of Energy Resources (DOER) on October 12, 2018, SRECTrade had been operating under the premise that facilities larger than 25 kW DC could submit their SQA and mechanically complete documentation “by no later than December 10, 2018”. It has been brought to our attention that the mechanically complete extension applications for facilities larger than 25 kW DC had to have submitted an SQA application by November 26, 2018.

The December 10th deadline is for the mechanically complete document to be added to the existing SQA.

SRECTrade recommends that all affected facilities submit their SMART Initial Application Period applications by 11:59pm ET tonight, November 30th.

Today, November 26th, at 12:00pm ET, the Solar Massachusetts Renewable Target (SMART) Program application portal opens to begin accepting Statement of Qualification Applications. Solar Tariff Generation Units (STGUs) can then apply during the Initial Application Period, which will last until 11:59pm ET on November 30, 2018.

All applications received between 12:00pm ET on November 26th and 11:59pm ET on November 30th will be considered to have been received at the same time for the Capacity Block placement queue. All applications received on or after 12:00am ET on December 1, 2018 will be reviewed on a first-come, first-served basis.

On October 24, 2018, CLEAResult (the SMART Program Administrator), the Massachusetts Department of Energy Resources (DOER), and the stakeholder electric distribution companies hosted a webinar providing a demonstration of the SMART Program application portal and instructions on how to submit an application. A recording of the webinar is available here.

Please note that today, November 26th, is a significant deadline for all projects seeking SREC-II qualification. Today is the deadline for projects larger than 25 kW DC to achieve mechanical completion and the deadline for projects smaller than or equal to 25 kW DC to receive Permission to Operate (PTO). Projects larger than 25 kW DC have until December 10, 2018 to submit their Statement of Qualification application demonstrating mechanical completion by November 26th. Projects smaller than or equal to 25 kW DC have until February 15, 2019 to submit their Statement of Qualification application. For more information regarding SREC-II qualification and application deadlines, please visit our previous blog post here.

Massachusetts DOER Announces SMART Program Effective Date

Posted October 12th, 2018 by SRECTrade.

November 30, 2018 Update: Due to this email from the Massachusetts Department of Energy Resources (DOER) on October 12, 2018, SRECTrade had been operating under the premise that facilities larger than 25 kW DC could submit their SQA and mechanically complete documentation “by no later than December 10, 2018”. It has been brought to our attention that the mechanically complete extension applications for facilities larger than 25 kW DC had to have submitted an SQA application by November 26, 2018.

The December 10th deadline is for the mechanically complete document to be added to the existing SQA.

SRECTrade recommends that all affected facilities submit their SMART Initial Application Period applications by 11:59pm ET tonight, November 30th.

On Friday, October 12th, the Massachusetts Department of Energy Resources (DOER) announced that the Solar Massachusetts Renewable Target (SMART) Program effective date is November 26, 2018. November 26th is now the deadline for facilities larger than 25 kW DC to become mechanically complete and for facilities smaller than or equal to 25 kW DC to receive their Permission to Operate (PTO). On November 26th, at 12:00pm ET, the SMART Statement of Qualification application portal will open to begin accepting Statement of Qualification Applications for prospective Solar Tariff Generation Units (“STGU”) seeking to qualify under SMART.

Facilities larger than 25 kW DC will have until December 10, 2018 to submit their documentation demonstrating mechanical completion. Once granted, mechanically complete extensions are indefinite; facilities should simply submit their Permission to Operate (PTO) documents once received to complete their statement of qualification application. As a reminder, facilities can demonstrate mechanical completion by submitting one of the following documents:

  1. Certificate of Completion
  2. Proof that a wiring inspection has been scheduled by a date shortly after November 26, 2018
  3. Affidavit signed by engineer of record stating that project is “mechanically complete”
  4. Other documentation deemed satisfactory by DOER

Facilities smaller than or equal to 25 kW DC will have until February 15, 2019 to submit an application demonstrating authorization to interconnect. In other words, the PTO must be dated on or before November 26, 2018, but the DOER application can be submitted up through February 15, 2019.

Please note that SRECTrade typically asks for complete applications to be received five (5) business days in advance in order to guarantee submission by the DOER deadline.

Massachusetts DOER Schedules SMART Information Sessions and Clarifies SREC-II Transition Status

Posted October 1st, 2018 by SRECTrade.

On September 26th, the Massachusetts Department of Public Utilities (DPU) issued an order approving the model Solar Massachusetts Renewable Target (SMART) Program. This action is the final regulatory step in launching the program and initiates the transition from the Solar Carve-Out II (SREC-II) Program to SMART.

Notably, on October 1st, the Massachusetts Department of Energy Resources (DOER) clarified that the SMART Program Effective Date remains to be determined and that the SREC-II application window is still open. The DOER also announced a series of stakeholder meetings later this month to provide additional information on SMART requirements and the program transition process.

SRECTrade strongly encourages stakeholders seeking to enroll their solar projects in SREC-II to obtain Permission to Operate or mechanical completion for their projects as soon as possible. As a reminder, the SMART Program Effective Date will be the deadline for projects smaller than or equal to 25 kW DC to obtain Permission to Operate and the deadline for projects larger than 25 kW DC to achieve mechanical completion. SRECTrade will continue to provide significant updates as they become available.

Massachusetts DOER Announces Final 2019 SREC Minimum Standards

Posted August 31st, 2018 by SRECTrade.

Update: On Wednesday, September 5th, the MA Department of Energy Resources (DOER) made some small corrections to the previously announced final 2019 Solar Carve-out (SREC-I) and Solar Carve-out II (SREC-II) Compliance Obligations and Minimum Standards. The corrections were made to also include a small number of SRECs that the DOER approved to be transferred into the SREC-I and SREC-II auction accounts between the DOER’s preliminary minimum standard announcement in July and its final minimum standard announcement in August. The original post has been edited to reflect the corrections.

On Thursday, August 30th, the DOER announced the final 2019 SREC-I and SREC-II Compliance Obligations and Minimum Standards. This announcement follows the results of the SREC-I and SREC-II Solar Credit Clearinghouse Auctions. The final announcement differs only slightly from the preliminary announcement in July.

Solar Carve-out (SREC-I)

The DOER has determined that the 2019 Compliance Obligation for the SREC-I program will be 797,674 MWh and that the Minimum Standard will be 1.7446%. The 2019 Minimum Standard for load under contracts signed before June 28, 2013 will be 1.0967%. The Determination of the CY 2019 Total Compliance Obligation and Minimum Standard, published by the DOER, outlines how this Minimum Standard was calculated.

Solar Carve-out II (SREC-II)

The DOER has also calculated the 2019 Compliance Obligation and Minimum Standard for the SREC-II program, which are 1,060,524 MWh and 2.3195%, respectively.

In addition, the DOER calculated the 2019 SREC-II Compliance Obligation and Minimum Standard for load under contracts signed after May 8, 2016 as 1,789,567 MWh and 3.9139%, respectively. The final SREC-II baseline Compliance Obligation and Minimum Standard are slightly lower than their preliminary counterparts, primarily due to two reasons:

  1. A reduction in the average capacity factor applied to estimated generation from 13.64% to 13.35% (using eight years of Massachusetts Production Tracking System production data)
  2. An improvement to the SREC-II production estimation formula to account for the loss of partial MWhs left over after a reporting period, since these partial MWhs do not result in the creation of partial SREC-IIs

The adjustment to the SREC-II production estimation formula decreased the projected number of SREC-IIs to be generated by over 36,000 MWh.

MA 2017 Solar Credit Clearinghouse Auction Result Announcement

Posted July 26th, 2018 by SRECTrade.

On July 26, 2018, the Massachusetts Department of Energy Resources (DOER) announced that all of the MA2017 SREC Is and SREC IIs submitted to the auction account were transacted in the first round of the Solar Credit Clearinghouse Auction (SCCA).

A total volume of 16,812 SREC Is were bid on across 21 unique bidders, creating more than sufficient demand to clear the available auction volume of 1,520 SREC Is.

A total volume of 74,813 SREC IIs were bid on across 16 unique bidders, creating more than sufficient demand to clear the available auction volume of 12,071 SREC IIs.

DOER and EnerNOC are in the process of certifying and finalizing the auction results. More information will be made available on the SCCA auction page in the coming weeks.

If SRECTrade submitted SRECs to the SCCA on your behalf, we will provide further notice on the status of your transaction once the DOER and EnerNOC provide us with finalized auction results.

Massachusetts DOER Announces Revised 2018 and Preliminary 2019 SREC Minimum Standards

Posted July 10th, 2018 by SRECTrade.

On July 10, 2018, the Massachusetts Department of Energy Resources (DOER) announced both preliminary 2019 SREC I and SREC II Minimum Standards and a revised version of the original 2018 SREC II Minimum Standard calculation. The 2018 SREC II Minimum Standards were reduced from 2.7802% to 2.6823% for load executed under contract between April 25, 2014 and May 8, 2016 and from 4.1661% to 4.0683% for contracts executed after May 8, 2016.

The DOER estimates a 2019 SREC I Minimum Standard of 1.1189% for load executed under contract prior to June 28, 2013 and, if the auction clears in the first or second round, 1.7809% for load executed under contract on or after June 28, 2013.

The DOER estimates a 2019 SREC II Minimum Standard of 2.3680% for load executed under contract between April 25, 2014 and May 8, 2016, and 3.9697% for load executed under contract on or after May 8, 2016. This also only applies if the auction clears the first or second round.

Details regarding this announcement can be found here. SRECTrade will be assessing the implications of this adjustment and informing our constituents accordingly.

Massachusetts SREC-II Application Timeline

Posted June 27th, 2018 by SRECTrade.

While the Solar Massachusetts Renewable Target (SMART) Program Effective Date is still to be announced by the Department of Energy Resources (DOER), the application timelines for SREC-II have been set.

As a reminder, the SMART Program Effective Date will be the deadline for facilities smaller than or equal to 25 kW DC to be interconnected and facilities larger than 25 kW DC to be mechanically complete. This means that documentation must be dated on or before the Effective Date, but applications can be submitted for some time after.

Facilities larger than 25 kW DC will have two weeks after the SMART Program Effective Date to submit their documentation demonstrating mechanical completion. Once granted, mechanically complete extensions are indefinite – facilities should simply submit their Permission to Operate (PTO) documents once they are received to complete their statement of qualification application.

Facilities smaller than or equal to 25 kW DC will have until November 15th to submit an application demonstrating authorization to interconnect. In other words, the PTO must be dated on or before the effective date, but the applications can be submitted to the DOER up through November 15th.

For more information please reference the DOER’s Current Status of the Solar Carve Out II Program page.