Archive for the ‘Massachusetts’ Category

Massachusetts Solar Carve-out Proposed Rule Changes Released

Posted February 28th, 2013 by SRECTrade.

On 2/27/2013 the Massachusetts Department of Energy Resources (DOER) released proposed changes to the RPS Solar Carve-Out program. The change-tracked version of the proposed rules can be viewed here. Interested parties can submit comments to DOER.SREC@state.ma.us with the word COMMENTS in the subject line from March 1st until 5:00 PM on March 25th. A public hearing will be held on March 22nd in the Gardner Auditorium, Massachusetts State House in Boston from 1:00pm to 3:00pm.

The proposed changes to the rules fall into two general categories: 1) updates to the existing program and 2) changes to smooth the approach to the 400MW program cap. The following is a brief summary of the proposed changes:

  • Change to allow anyone to deposit an SREC in the Clearinghouse Auction, not just the original SREC owner.
  • Clarification that reminted SRECs coming out of a Clearinghouse Auction can’t be submitted to any future auctions.
  • Direction to the DOER to develop an assurance process that will allow proposed systems a spot under the 400MW limit as long as they follow certain steps. This will probably be very similar to the net metering process that was recently enacted.
  • Details were provided on the conditions necessary for a rebuilt system to qualify as new.
  • A change was made to the formula used to determine each year’s SREC requirement, removing the “SACP volume” portion of the formula.  In the original rule, the next years’ standard was adjusted by subtracting SACPs paid in the two years prior. The formula change would be retroactive to 2013, although there is protection for electric distribution companies with existing contracts. It also includes a novel mechanism by the DOER to purchase a like number of SRECs protected under this clause so that there will be no impact on total demand from the sheltering of existing contracts. Click here for a more comprehensive explanation of this formula adjustment. 
  • Some minor changes were made to the calculation used to determine annual SREC requirements after reaching 400MW using the existing base to determine the capacity factor rather than the calculated number used before. Also minor changes on what happens the last year of the program if SRECs are entered into the auction that year.
For more specific details on these changes and their impact on the MA SREC market, feel free to email or call us at SRECTrade.

Massachusetts Solar Carve-Out Rulemaking and Policy Development Update

Posted February 22nd, 2013 by SRECTrade.

The Massachusetts Department of Energy Resources (DOER) sent an email update today (2/22/2013) with clarifications on how the DOER intends to address the approach of the 400 MW cap to the existing Solar Carve-Out program as well as a timeline for establishing a solar policy beyond the existing 400 MW Solar Carve-Out.  Read the bulletin here. Currently the Massachusetts Solar Carve-Out program is limited to 400 MW of installed eligible solar capacity.

Highlights of the bulletin are:

Plans for the approach of the 400th MW

– DOER to submit a Public Notice on March 1, 2013 outlining a queuing system for SREC eligible projects as the Solar Carve-Out approaches the 400 MW cap

– Following public comment the DOER intends to firmly establish any queuing system for SREC eligible projects before the DOER Solar Credit Clearinghouse Auction in June

Plans for a solar program after the 400th MW

– DOER to present a post 400 MW policy proposal at a stakeholder meeting in March 2013 (date to be announced)

– A finalized post-400 MW policy will be adopted in April or May

SRECTrade will closely follow the development of these two DOER initiatives. Stay tuned to our blog for details as they emerge.

* Update, 2/27/2013: The DOER sent a follow up email today with a link to the proposed amendment for Solar Carve Out program. A public hearing will be held on March 22, 2013 at the Massachusetts State House in Boston in the Gardner Auditorium. The public comment period for written comments will run from March 1, 2013 to March, 25, 2013.

Massachusetts 10 Year Opt-in Term Deadline

Posted February 6th, 2013 by SRECTrade.

Summary
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.

Details
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. 

SRECTrade Webinar for Massachusetts Installers

Posted November 16th, 2012 by SRECTrade.

SRECTrade will host an hour long webinar for Massachusetts solar installers on Wednesday, 12/5 at 2 pm EST.  To register for the webinar please click here.

The webinar will be co-moderated by SRECTrade’s CEO Brad Bowery,  Lisa Wadsworth and Sam Rust. The presentation is slated to last 30-40 minutes, with the the rest of the webinar open for questions. Topics covered in the presentation will be:

  • Overview of customer options
  • Account set up best practices
  • SREC market mechanics
  • Pricing trends and market outlook
We look forward to seeing you online Wednesday, 12/5 at 2 pm EST!

About the presenters:

Brad Bowery is the CEO of SRECTrade, a company that he has managed since 2008. Under Brad’s stewardship SRECTrade provides SREC services for over 5,000 facilities and 70+ MW of aggregated solar capacity. Brad holds an MBA from the Stanford Graduate School of Business.

Lisa Wadsworth is the Applications Manager for SRECTrade and is responsible for managing SRECTrade’s team of employees dedicated to navigating the complex SREC registration process across all of the SREC markets.

Sam Rust is the Director of Channel Operations for SRECTrade and works closely with the company’s installer partners to improve SRECTrade’s services.

MA Gov. Deval Patrick Signs Law Adjusting Net Metering Cap

Posted August 30th, 2012 by SRECTrade.

Massachusetts Bill SB 2395, “Relative to Competitively Priced Electricity in the Commonwealth,” was signed into law on August 3, 2012 by Governor Deval Patrick.  The new legislation clarifies some issues related to meeting the Massachusetts Renewable Portfolio Standard (RPS) goal of 22.1% by 2020. Its purpose is to further bolster the existing RPS goals by:  1) increasing the net metering cap; 2) expanding requirements for the EDC long-term contract program and 3) limits entities from owning more than 25 MW of solar. *Please see note below. While this legislation does not explicitly impact the solar carve out portion of the Massachusetts RPS, it does impact net metering policy in MA, a key facet of solar project development. By raising the net metering cap, there is now more room for the development of solar projects at any scale. If development continues to exceed the yearly capacity goals set aside by the DOER, then SREC prices should remain suppressed relative to the SACP.

The legislation doubles the net metering cap to 6%, with 3% allocated for public and private projects each. As Massachusetts was already close to the 3% net metering cap, the bill was essential to ensure renewable energy project development of all types throughout the rest of the year. In addition to the increase in the cap, the bill also states that Class I facilities that are less than 10 kW (single-phase) and <25 kW (3-phase) in capacity will be exempt from the net metering cap altogether. The <10 kW/ 25 kW Class I REC exemption ensures that developers of residential and small commercial facilities will not need to take in to consideration the net metering cap. Class I RECs include RECs produced from most renewable energy technologies (solar, wind, tidal, biomass etc.) that were operational after December 31, 1997. (Source: DSIRE)

*A previous version of this post included language about a property tax exemption for qualified renewable energy facilities. The property tax exemption portion of SB 2395 was not included in the final bill.

MA DOER Announces 2013 SREC Requirement

Posted August 29th, 2012 by SRECTrade.

Today, the MA DOER announced the 2013 compliance year (January 1 – December 31, 2013) Solar Renewable Energy Credit (SREC) requirement. Massachusetts’ SREC requirement is set each year by a formula that takes into consideration the current year SREC obligation plus the projected SREC generation for the current year less the SRECs generated in prior years multiplied by 1.3. Additional adjustments are then made for prior year’s Alternative Compliance Payment (ACP) volume, banked SREC volume, and DOER Credit Clearinghouse auction volume. The detailed formula for 2013 is as follows:

Total Compliance Obligation 2013 = Total Compliance Obligation 2012 + [Total SRECs Generated (projected) 2012 – SRECs Generated (actual) 2011] x 1.3 – ACP Volume 2011 + Banked Volume 2011 + Auction Volume 2011

MA2013 Compliance Obligation

The MA2013 SREC requirement has been set at 135,495 SRECs. This figure does not take into consideration exempt load based on the TransCanada settlement reached during the first year of the MA SREC market. In the calculation, the DOER provided the effective reduction in SREC Demand for 2013 at 4,784. This means that, under the announced 2013 requirement, the actual number of SRECs needed to be purchased under the 2013 obligation will be equal to 135,495 less 4,784; 130,711 SRECs.

The 2013 Requirement Might Increase

In coordination with its announcement, the DOER also stated its intention to begin a rulemaking process to address the following:

1) Formally insert the 10 Year Solar ACP schedule into regulation;

2) Adjust the formula above to remove the term that subtracts “ACP Volume” from prior years.

The DOER stated its intention to adjust the formula would retroactively apply to the 2013 SREC requirement. The removal of this term from the formula would increase the SREC requirement from 135,495 to 189,297 SRECs required in 2013. Taking into consideration the effective reduction of 4,784, that would put the net 2013 requirement at 184,513.

The table below demonstrates the current formula requirement vs. the proposed formula requirement:

The DOER noted their plans to begin the rulemaking process in September 2012. The DOER welcomes any comments on the announcement prior to beginning the process. Comments can be sent to DOER.SREC@state.ma.us by 5:00pm on September 14th.

MA2012 SREC Auction Closes at $271.05/SREC

Posted July 17th, 2012 by SRECTrade.

The Q1 2012 (January – March 2012 generation) MA SRECs were issued on July 15, 2012. Unlike other SREC markets, the MA Solar Carve-Out program mints SRECs quarterly, three and a half months after the close of the calendar quarter. In coordination with the Q1 2012 issuance, SRECTrade recently held a separate auction for MA2012 SRECs.

The auction order window closed on Monday, July 16th at 5:00 p.m. Eastern. SRECs were transacted at a price of $271.05 per SREC. The clearing price, below the Department of Energy Resources (DOER) Solar Credit Clearinghouse auction price, is a result of the oversupply of SRECs the MA2012 market will experience. According to NEPOOL GIS, 14,479 MA2012 SRECs were issued for Q1 2012 generation. Approximately 15% of this volume was available through SRECTrade in the last auction period. As a result of the price, the auction saw light volumes trade hands given the gap in pricing expectations between buyers and sellers.

The next SRECTrade Solar REC auction order window closes on Thursday, August 2 at 5 p.m. ET. This auction will cover all of the SREC markets including DC, DE, MA, MD, NJ, OH, and PA. The order window is currently open. All buyers and self-serve sellers can login here to place an order. Sellers utilizing SRECTrade’s management service, EasyREC, will have orders automatically placed on their behalf. If these sellers need to make changes to their minimum offer prices, they must do so prior to the 5:00 p.m. close on August 2nd.

The next issuance of MA Eligible SRECs will be on October 15, 2012, and will cover the second quarter of 2012 eligible SRECs.

Massachusetts SREC Market Update – June 2012

Posted June 20th, 2012 by SRECTrade.

For a PDF copy of this analysis click here: Massachusetts SREC Market Update – June 2012

Introduction

The Massachusetts 2012 compliance year began on January 1, 2012. SREC issuance for Q1 2012 generation (January – March 2012) will take place on July 15, 2012. Solar REC under supply in previous compliance periods led to SRECs pricing just below the Solar Alternative Compliance Payment (SACP). Pricing right below the SACP is common in the early stages of a market with a Solar Carve-Out requirement in a state’s Renewable Portfolio Standard (RPS). As the market matures and attracts more participants, typically due to high SREC prices, the market sees an overbuild of solar which quickly turns to an oversupplied market and pricing declines.

As the Massachusetts 2012 compliance year moves on, the prospect of oversupply has become apparent. In March 2012 we provided an update on MA solar supply, taking a closer look at three different potential install scenarios for the 2012 period. This update takes a similar approach, analyzing how various project size categories are impacting the market and what the forecast scenarios mean for 2012 supply. Additionally, we will look at how these scenarios could impact the 2013 SREC requirements.

Solar Installed Can Reach Oversupply – Current and Historic Capacity

The chart below demonstrates the beginning balances of MW capacity (in gray), the added MW capacity (in green), and the total capacity (above each bar) on a monthly basis going back to January 2011. The balances below were derived from the Department of Energy Resources’ (DOER) RPS Solar Carve-Out Qualified Units report as of June 7, 2012. Monthly capacity balances are based on the Commercial Operation Date noted in the report.

Converting 2012’s SREC requirement to an average balance of online MW capacity, we estimate approximately 65.0 MW needed to be operational all year long. Note, this takes into consideration the exempt load resulting from the TransCanada settlement. Taking the beginning balance of capacity as of January 1, 2012 and the ending balance of capacity as of May 31, 2012, the average capacity online for the 2012 year to date is 61.2 MW. During this five month period, 21.5 MW were installed, compared to 10.3 MW, a growth rate of 109.0%, for the same period in 2011. Additionally, the DOER noted the MWh reported to the Production Tracking System (PTS) from January 2012 to May 2012.

As shown above, the MWhs reported through May 2012 are approximately 40% of this year’s SREC obligation. Historically, the MWh reported to the PTS have typically been understated as compared to the actual number of SRECs issued in NEPOOL GIS. With less than half way through the year, and some of the most productive months ahead of us, it appears that the generation reported and the expected remaining generation is in line to exceed this year’s obligation.

500 kW+ Projects See Growth – Projects Installed by Size Category

The last time we evaluated MA projects by size category, projects less than 500 kW saw substantial growth. In addition to continued growth in these categories, MA solar has also seen growth in projects greater than 500 kW. In the early stages of the MA SREC market, projects greater than 500 kW quickly have an impact on SREC oversupply. The table below shows operational projects based on their DOER reported commercial  operation date as of June 30, 2011 and June 1, 2012.

Three Cases Point to Oversupply in 2012 – Capacity Forecast Scenarios

Over the Last Twelve Months (LTM),  June 2011 – May 2012, average operational capacity installed has been 4.1 MW per month. The cases presented below apply three scenarios for the remaining months in the compliance period (June – December 2012):

1) Half of the LTM average capacity is added per month: This equals approximately 2.0 MW/month for the remaining months left in 2012. Note, the DOER’s June 7, 2012 data showed 2.3 MW installed in June alone, thus we can be assured that at least this capacity and likely more will come online in June.

2) LTM average capacity remains the same per month: This equals approximately 4.1 MW/month for the remaining months left in 2012.

3) Two times the LTM average capacity is added per month: This equals approximately 8.2 MW/month for the remaining months left in 2012.

As demonstrated in the cases above, each scenario forecasts oversupply for the 2012 period. Furthermore, adjusting Case 1 to reflect no solar installed in the 2nd half of the year, the market would still see oversupply of approximately 5,400 SRECs, or 7.3% of the estimated MA2012 requirement.

This outlook has had downward pricing pressure on both the 2012 vintage as well as future periods. 2012 SRECs have traded down from 2011 prices, recently trading around $300/SREC. Additionally, multi-year forward contracts for delivery beginning in 2013 are trading below the Solar Credit Clearinghouse Auction price; below $200/SREC.

Not Much Solar Needed in 2013 – Forecasting MA’s 2013 SREC Compliance Obligation

In August 2012, the DOER will release a statement announcing the 2013 compliance year obligation. The SREC compliance obligation is set by a formula per regulation 225 CMR 14.07 (2)(d). The formula for 2013 is currently set as follows:

Total Compliance Obligation 2013 = Total Compliance Obligation 2012 + [Total SRECs Generated (projected) 2012 – SRECs Generated (actual) 2011] x 1.3 – ACP Volume 2011 + Banked Volume 2011 + Auction Volume 2011

The table below estimates what the 2013 requirement may be under each scenario presented above. It is important to note the 2012 Compliance Obligation is presented without exemptions as it was done for 2011 when calculating the 2012 obligation. Additionally, the ACP volume for 2011 was determined using our estimated 2011 requirement after exemptions less 2011 actual generation, as this would be reflective of the full number of ACPs paid.

The forecast figures demonstrate that a substantial amount of generation, ~36,300 SRECs, would be reduced from the 2013 requirement given the volume of ACPs paid for 2011 compliance requirements. In Case 3, this would put the market at oversupply prior to the beginning of 2013, while Case 1 and Case 2 would need less than the current LTM average installed capacity per month to be installed in 2013.



Last Chance to Sell MA 2011 SRECs

Posted May 18th, 2012 by SRECTrade.

On July 15, 2012 the first 2012 vintage MA SRECs will be minted. To date, all transactions of MA SRECs in 2012 have been for 2011 vintage SRECs. Short of something unanticipated the 2011 market will remain under-supplied and MA 2011 SRECs (if they have not yet been sold) should continue to sell close to SACP pricing.

The DOER recently issued a press release reminding SREC sellers that they have until June 15th to sell SRECs on the open market. Any SRECs not sold on the open market will need to be placed in the DOER’s “last chance” Solar Credit Clearinghouse Auction and put up for the sale at the mandated $300 per SREC offer. Remaining SRECs not placed in the auction will be automatically retired and will not be eligible for future transactions.

SRECs transacted through SRECTrade have consistently sold for $540 per SREC. Please do not hesitate to contact us if you are a seller with unsold Massachusetts SRECs.  For a history of MA SREC pricing in the SRECTrade auctions click here and scroll to the bottom of the page.

MA2011 SREC Auction Closes at $540/SREC

Posted April 18th, 2012 by SRECTrade.

The Q4 2011 (October – December 2011 generation) MA SRECs were issued on April 15, 2012. Unlike other SREC markets, the MA Solar Carve-Out program mints SRECs quarterly, three and a half months after the close of the calendar quarter. In coordination with the Q4 2011 issuance, SRECTrade recently held a separate auction for MA2011 SRECs.

The auction order window closed on Monday, April 16th at 5:00 p.m. Eastern. SRECs transacted at a clearing price of $540.00 per SREC. The clearing price, more than 98% of the 2011 Solar Alternative Compliance Payment (SACP), represents a strong demand for MA2011 SRECs due to a shortfall of supply in the market.

The next SRECTrade Solar REC auction order window closes on Tuesday, May 1 at 5 p.m. ET. This auction will cover all of the PJM SREC markets including DC, DE, MD, NJ, OH, and PA. The order window is currently open. All buyers and self-serve sellers can login here to place an order. Sellers utilizing SRECTrade’s management service, EasyREC, will have orders automatically placed on their behalf. If these sellers need to make changes to their minimum offer prices, they must do so prior to the 5:00 p.m. close on May 1.

The next issuance of MA Eligible SRECs will be on July 15, 2012, and will cover the first quarter of 2012 eligible SRECs. The MA market continues to see a lot of installation and development activity, which has already put downward pressure on the price of 2012 vintage SRECs. Recent bid and offer activity in the over the counter markets has been at levels of approximately 50-65% of the 2012 $550 Solar Alternative Compliance Payment (SACP).