Posts Tagged ‘400 MW Cap’

MA DOER Updates – Eligible Projects Report

Posted July 12th, 2013 by SRECTrade.

The DOER sent out an email today, Friday, July 12, 2013 announcing two things: 1) the final version of the Pending SQAs list is available and 2) that the RPS Class I Emergency Regulation (225 CMR 14.00) will be posted  July 19, 2013 to the Massachusetts Register. A public hearing on the Emergency Regulation will be held on July 26th from 1 to 3 pm at Gardner Auditorium in Boston. The updated Pending SQA list can be found here and the DOER email can be found here.

Some numbers from the Pending SQA list

The Pending SQA list shows that 340.8 MW of capacity was disqualified for failing to show proof of a signed Interconnection Service Agreement (ISA) dated no later than 6/7/2013, but 277.2 MW remain eligible or eligible pending permission to operate (PTO) for the program. If we take into account the 401.9 MW listed as already qualified for the current SREC program, then we come to a rough total of 679 MW eligible or qualified for a program that was originally supposed to be limited to 400 MW! For more information on the 400 MW cap and the current status of the program read our previous posts on the subject.

Eligible or Eligible pending PTO means that a system has submitted paperwork for the current SREC program and is either <100 kW in capacity or is over 100 kW in capacity and submitted a signed ISA dated no later than 6/7/2013.

Qualified means that a project application was submitted before the 400 MW capacity cap was reached with all of the appropriate requirements in place. Of these qualified projects 221.6 MW are operational and 180.3 MW are not yet operational.

We expect some attrition may occur as projects that are not yet operational fail to meet the completion requirement by 12/31/2013 or fail to demonstrate 1) the project has expended 50% of its construction costs or 2) delays occurred as a result of the local interconnecting utility. All projects granted an extension must be constructed by 6/30/2014. This list gives market participants a first glimpse at understanding the upper limit of the capacity that could be allowed under the current program. The DOER will use these numbers to sort out the SREC compliance requirement for 2014, using a formula that takes into account the build rate to date.

Massachusetts Emergency Regulations Announced Today

Posted June 28th, 2013 by SRECTrade.

Today, the Department of Energy Resources (DOER) announced the Emergency Regulations for the Solar Carve-out program. Market contributors expected the program to reach its 400MW cap sometime in 2014, yet on May 29th the DOER announced the Massachusetts SREC program surpassed its 400MW cap. Today’s announcement outlines MA’s solar development rules under the existing program until the DOER finalizes the second SREC program.

These emergency regulations are consistent with the criteria outlined at the DOER’s June 7th meeting. A summary of these new regulations are provided below and more details can be found in the DOER’s letter to Solar Carve-out Stakeholders here.

Projects 100kW or less will be qualified under the current program as long as they have received Authorization to Interconnect by December 31st

  • If the second SREC program is not completed by December 31st these system can become registered anytime prior to the effective date of the new program

Projects over 100kW must have received a signed Interconnection Services Agreement (ISA) by June 7th and must have a Receipt of Interconnection by December 31st

  • Project ISA’s dated no later than 6/7/2013 must be submitted to the DOER by July 5th
  • Projects may be granted extensions until June 30, 2014 if they can demonstrate at least 50% of their construction costs are expended by December 31, 2013
  • Projects can also be granted an extension if they can demonstrate that the missing Authorization to Interconnect is due to a delay from the local distribution company

A current status on the existing Solar Carve-out Program as well as a list of projects that have received their Statement of Qualification under the existing program can be found here. If large projects are listed as pending on the DOER’s Qualified Projects List they have one week from today to make sure all the necessary documents are in order. The DOER will announce the final qualified projects list July 15th 2013.

These rules will take effect immediately, but are not yet permanent. The DOER has 90 days to ensure these regulations meet the administrative procedure law and will soon announce a plan for a public hearing and comment period as part of that procedure. The DOER will announce the new total MW program cap for the first SREC program in July 2014.

Massachusetts DOER 400 MW Cap Stakeholder Meeting

Posted June 7th, 2013 by SRECTrade.

Today, the DOER hosted a meeting to address how the current SREC program will be finalized and the implementation of a the state’s next SREC program. The MA SREC market was thrown a curve ball last week when the DOER announced on May 29th that the current SREC program had reached its 400 MW capacity. Many industry participates expected the program to be closed to applicants sometime in 2014. In fact, the DOER planned to announce on June 7th, a process for applicants to ensure project eligibility under the current 400 MW SREC program.

The meeting today outlined the criteria for managing projects that are installed but not listed as eligible under the original application guidelines for the current program and those projects that have applied but are not yet installed.

In addition to today’s meeting, the DOER promulgated rule changes proposed in February of this year (see blog post here). The details of the implemented rules can be found on the DOER’s website here.

Clarifications on project eligibility for the current SREC program

The DOER plans to enact emergency rules for the current 400 MW Solar Carve-out program. The initial outline of those rules are listed below and additional details can be found here on the DOER’s website. A link to the presentation slides from today’s meeting can be found here. We will update updates on these rules as the DOER provides further official clarification.

The DOER is expanding the current program capacity limit to include project applications that meet certain criteria. To do this this they are splitting applications up into two categories based on facility size: 1) projects equal to or less than 100 kW and 2) projects greater than 100 kW.

Projects equal to or less than 100 kW

  • Applications for facilities equal to or less than 100 kW which have an authorization to interconnect approval and have submitted an SQA prior to the effective date of MA’s next solar carve-out program will be provided an SQA. We believe the effective date will be 1/1/2014 at the earliest, but look to the DOER to provide further clarification.

Projects greater than 100 kW

  • Projects that are listed after the 400 MW capacity cap demarcation on the pending SQA list will qualify if they they meet the following criteria: 
    • Fully executed Interconnection Service Agreement (ISA) application dated June 7, 2013 or earlier.
    • Receive an authorization to interconnect by 12/31/2013, or an extension to 6/30/2014 can be applied for if at least 50% of the project budget is spent by 12/31/2013.
    • Projects that can demonstrate interconnection applications have been delayed by the distribution utility can request further extensions. 

Clarifications on the next SREC program

The DOER indicated that the next phase of the Massachusetts SREC market will be a modification of the current program. The Commonwealth has an overall goal of 1,600 MW of installed solar capacity under the current SREC program and the future SREC program. The final size of the next SREC program will be determined by how many facilities meet the criteria for eligibility outlined above for the current program. For example if 500 MW of capacity is approved in the current program, then the next SREC program will allow for 1,100 MW of eligible capacity. The DOER emphasized that the next program’s design will take in to account a goal to minimize the impact of the program on rate rate payers and eventually bring the SREC market in line with the Massachusetts Class I REC market.

To do this the DOER plans to implement a series of key design features based on project location, size, and a new tool that the DOER calls the Adjusted SREC factor. Smaller projects will be granted SRECs that carry an inherently higher value than larger projects. Additionally, it was proposed that a greater SREC factor will be given to projects installed on brownfields and other specially designed zones. The DOER intends to adjust the SREC factor over time for projects as more capacity comes to market and the cost to install decreases.

The DOER also intends to moderate growth by capping the capacity for eligible project applications on a year to year basis using managed growth provisions to throttle supply.

The DOER mentioned that a separate, but similar Solar Credit Clearinghouse Auction will provide a price support mechanism. All projects will have a 10 year opt-in term. The price set under this mechanism was not mentioned. The DOER did indicate that it is waiting for the legislature to determine the outcome of H2915, a bill that if passed, would require the distribution utilities to support a minimum SREC price in years where there is an over-supply of SRECs.

Preliminary SACP prices were presented as well. The SACP is the penalty price that electricity suppliers in the MA market must pay if they do not meet their renewable energy compliance requirement with SRECs. The proposed schedule is listed below:

2014: $375
2015: $350
2016 (and beyond): $325

We look to the DOER to continue to clarify the application rules for the current SREC program as well as the general market design and implementation period for the next SREC program. We express some concern over the administrative complexities presented by the proposed SREC II program. It is important that the DOER and stakeholders understand that however the new program is structured, participants should focus on pursuing administrative efficiency in transacting SRECs and managing solar assets. SRECTrade will stay in close touch with the DOER and continue to provide updates on this blog.


Massachusetts 400 MW Cap Update

Posted June 3rd, 2013 by SRECTrade.

DOER to file emergency regulation

On Monday evening (6/3/2013) the DOER sent out a second email updating stakeholders on the situation surrounding the state’s solar requirements surpassing the current 400 MW goal. The email included a link to the latest data on the status of projects’ applications for the 400 MW Solar Carve-out. Additionally, the statement noted the DOER’s intentions to file emergency regulation sometime this month. Details on the emergency regulation proposal will be provided at a stakeholder meeting this Friday, June 7th. In addition to the emergency regulation, the meeting will cover the status of the post 400 MW solar program.

400 MW Solar Carve-out filled with non-operational project applications

On May 29th SRECTrade reported on an email from the Massachusetts DOER stating that the Massachusetts SREC market had reached the 400 MW goal. This came on the heels of a May 20, 2013 qualified projects list released by the DOER that showed only 287 MW of qualified capacity registered, which left room for 113 MW of new qualified capacity. Of the 287 MW capacity, 69.1 MW was listed as non-operational. However, the Pending SQAs list made public today shows that an additional 110.8 MW of non-operational projects were listed as qualified or administratively complete by the DOER between the issuance of the 2 reports. In total 179.9 MW or 45% of the qualified or administratively complete solar capacity is currently listed as non-operational.

SRECTrade to attend the DOER’s stakeholder meeting on June 7th

SRECTrade continues to closely monitor events and will have a representative at the DOER’s stakeholder meeting on Friday, June 7th. We will provide any relevant updates as they become available.

MA DOER Solar Stakeholder Update – 400 MW Cap

Posted May 29th, 2013 by SRECTrade.

The MA DOER sent out an email on Wednesday, May 29th to MA solar stakeholders announcing that more than 400 MW of SREC program applications are now administratively complete. The email can be read here. In total 550 MW of applications have either been qualified or are under review. The most recent data released (5/20/2013) by the DOER shows that 217.9 MW of applications are qualified and operational, suggesting that over 180 MW of capacity is qualified and not yet operational.

Below are the key points:

  • The DOER will announce the rules for a new 1,200 MW capacity program shortly.
  • 550 MW of capacity has applied for an SQA under the current 400 MW program.
  • Approximately 400 MW is defined as administratively complete.
  • The DOER will announce no later the June 4th a current list of all projects that have or will receive a Statement of Qualification. It will also post a list of projects, in order of their eligibility for qualification, that have SQAs deemed administratively complete but are beyond the 400 MW cap of qualified capacity, as well as a list of pending applications under review.
  • The DOER will continue to accept applications and allow two weeks for applicants to address any deficiencies before rejecting the applications. The DOER expects that applications received on or after June 7th, the anticipated promulgation date of the new regulation, will be reviewed under the revised regulation.
  • Some of the non-operational administratively complete and incomplete SQA applications are likely to be rejected or otherwise taken out of the application queue by project owners that are not yet prepared for construction.

What SRECTrade is doing

SRECTrade will continue to process applications with the DOER pending any clarification that applications will not be accepted. All applications that have been submitted to SRECTrade for SQA paperwork have been submitted to the DOER and will be finalized under the normal procedures. Further clarifications will be sent to our clients and partners as the DOER releases more information. Until then we will remain diligently attuned to any news from the DOER and other stakeholders.

What is the 400 MW Cap?

400 MW of installed PV capacity in Massachusetts is eligible for the current Massachusetts SREC program. Projects that are deemed eligible by the DOER to participate in the current program are allowed 40 quarters from their eligibility start date (defined by their SQA application) to produce SRECs and qualify for DOER Solar Credit Clearinghouse Auctions. Projects that are installed and registered after the 400 MW cap is reached will be eligible for another program that the DOER will outline shortly.

Massachusetts Market Update Webinar

Posted April 24th, 2013 by SRECTrade.

MA SREC Webinar May 15 2013SRECTrade will host a webinar covering the Massachusetts SREC market on Wednesday, May 15, 2013 at 2 pm ET. The webinar will cover the rules and timeline for the DOER Solar Clearinghouse Auction.  Additionally, information provided by the DOER concerning applications eligible for the current 10 year opt-in term will also be reviewed. Lastly, as the program’s 400 MW cap is approached, the DOER will be implementing queuing and registration requirements. These intricacies will also be discussed. To register for the webinar please follow this link. The webinar recording will also be posted to SRECTrade’s blog.

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.