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DOER Files SMART Program Emergency Regulation

Posted June 5th, 2017 by SRECTrade.

On Monday, June 5th, the MA Department of Energy Resources (DOER) filed an emergency regulation to implement the Solar Massachusetts Renewable Target (SMART) Program. The regulation is directed toward supporting the development of an additional 1,600 MW of solar energy generating facilities via a declining block program.

Although the emergency regulation takes effect immediately, it can only remain in effect for three months. The emergency regulation is a placeholder, pending a full rulemaking proceeding conducted by DOER, at which time the final program rules will be established. Following the conclusion of the DOER’s rulemaking process, the Department of Public Utilities (DPU) will need to conduct a proceeding for the DPU’s approval of the tariffs filed by the Electric Distribution Companies. Only after this rulemaking and proceeding take place will the SMART program be in effect. Accordingly, the SREC-II program remains in effect for all eligible solar facilities.

As a result of this implementation schedule, it is expected that solar facilities will be eligible to qualify for the SREC-II program through the end of Quarter 1, 2018.

For more information on the SMART program, please feel free to reference our last blog post on the topic here. The DOER’s official notice regarding this emergency regulation is available here.

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DOER Announces Final SREC-II Factor Guidelines

Posted March 27th, 2017 by SRECTrade.

On Thursday, March 23rd the DOER provided an update on the finalized SREC-II program SREC Factors for projects over 25 kW that have not previously qualified for an SREC-II extension.

All SREC-II facilities that have a Statement of Qualification (SQA), but have not yet received an extension, will have their SQAs rejected. New applications may be submitted for these facilities, however, to seek an extension under these new guidelines. Any extension granted will be effective until March 31, 2018 at the following factors:

new-market-factors

Please note that SREC-II systems with a capacity equal to or less than 25 kW will still receive an SREC Factor of 0.8, so long as they receive their authorization to interconnect before the effective date of the SMART program.

Facilities eligible for the extension are those that have not already received either a mechanically complete or 50% construction cost extension; facilities that can demonstrate that they are mechanically complete or commercially operational by March 31, 2018 will receive their respective SREC Factor listed above.

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MA SREC-II Extension Webinar

Posted December 13th, 2016 by SRECTrade.

Earlier today, SRECTrade hosted a webinar covering the current state of the Massachusetts SREC-II program, key deadlines for qualifying systems under SREC-II, and SRECTrade application processes.

The application window is currently open for all MA systems, regardless of size, although qualification deadlines are approaching. Please feel free to reference SREC-II Extension Application Instructions HERE.

For access to the presentation slides, please click here: MA SREC-II Extension Webinar. To view a video recording of the webinar, please click the image below.

This document and recording is protected by copyright laws and contains material proprietary to SRECTrade, Inc. It or any components may not be reproduced, republished, distributed, transmitted, displayed, broadcast or otherwise exploited in any manner without the express prior written permission of SRECTrade, Inc. The receipt or possession of this document does not convey any rights to reproduce, disclose, or distribute its contents, or to manufacture, use, or sell anything that it may describe, in whole or in part. If consent to use these materials is granted, a link to the current version of this document on the SRECTrade website must be included for reference.

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MA SREC-II Installer Webinar

Posted December 12th, 2016 by SRECTrade.

SRECTrade will be hosting a webinar this Tuesday, December 13th, at 2:00 PM EST. The webinar will cover the current state of the Massachusetts SREC-II program, key deadlines for qualifying systems under SREC-II, and SRECTrade application processes to consider as the program’s close approaches.

To attend the webinar click HERE to register. A recording will be made available on SRECTrade’s blog for those unable to attend.

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MA DOER Seeking Comments on Next Generation Solar Incentive Straw Proposal

Posted October 25th, 2016 by SRECTrade.

On September 23, 2016, the Massachusetts Department of Energy Resources (DOER) presented its Straw Proposal to outline its vision for the next solar incentive program for the state. The DOER is proposing to shift away from the state’s successful SREC program, which has created one of the largest and most robust solar markets in the country.

Under the DOER’s proposal, a declining block feed-in-tariff would be established in regulated utility territories, and a separate program would be created for municipal light districts. Moving away from the current market-based framework will impose a substantial transition burden and introduce new costs to participants. The shift to a completely different program will have a negative impact on the viability of the solar industry in the interim and poses uncertainty moving forward.

Massachusetts has installed more than 1,200 MW of operational solar capacity to date and was ranked 2nd in the nation in total solar industry employment in 2015. Replacing the current market-based framework with a declining block feed-in-tariff will not only be costly to all stakeholders, but it will also fail to satisfy the DOER’s objective to “provide clear policy mechanisms that control ratepayer costs and exposures”. By imposing this new and complicated model, the DOER will force the state’s many market participants to manage, understand, and abide by multiple programs at once. This will undoubtedly increase soft costs and increase administrative burden across the industry.

In contrast, establishing an SREC-III program would allow the state’s solar industry to continue relying on a market-based policy to set incentive levels and forge ahead on its path to a stable, equitable, and self-sustaining solar market. By making adjustments to SREC factors, market sectors, the SCCA and SACP, the Commonwealth can continue to benefit from the successful SREC model and preserve the progress it has made since SREC-I was implemented six years ago.

SRECTrade encourages all stakeholders in the Massachusetts solar market to submit comments in support of a smooth transition to another successful SREC program. Comments can be submitted to the DOER via email at DOER.SREC@state.ma.us and must be submitted by this Friday, October 28th.

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DOER Announces Final 2017 Compliance Obligation and Minimum Standard

Posted September 1st, 2016 by SRECTrade.

On Wednesday, August 31, the Massachusetts Department of Energy Resources (DOER) announced the final 2017 Solar Carve-out (SREC-I) and Solar Carve-out II (SREC-II) Compliance Obligations and Minimum Standards. This announcement follows the results of the SREC-I and SREC-II Solar Credit Clearinghouse Auctions.

Notably, this announcement differs greatly from the preliminary announcement in July. In particular, the DOER announced that the final SREC-II Minimum Standard for load under contracts signed prior to May 8, 2016 is 2.0197% (969,635 MWhs), reduced from 2.2960% (1,102,311 MWhs).

Solar Carve-out (SREC-I)

The DOER has determined that the 2017 Compliance Obligation for the SREC-I program will be 783,183 MWh and that the Minimum Standard will be 1.6313%. The 2017 Minimum Standard for load under contracts signed before June 28, 2013 will be 0.9861%. The Determination of the CY 2017 Total Compliance Obligation and Minimum Standard, published by the DOER, outlines how this Minimum Standard was calculated.

SREC-I Min Std

Solar Carve-out II (SREC-II)

The DOER has also calculated the 2017 Compliance Obligation and Minimum Standard for the SREC-II program, which are 1,374,406 MWh and 2.8628%, respectively. The DOER outlined how this preliminary Minimum Standard was determined in its “CY 2017 Calculation of Minimum Standard Guideline”.

SREC-II Min Std

Since all Retail Electricity Suppliers are exempt from additional obligations resulting from the expansion of the SREC-II Program Capacity Cap, the DOER established a baseline Compliance Obligation and Minimum Standard for load under contracts signed on or prior to May 7, 2016. The DOER’s calculation of the Final 2017 Compliance Obligation and Minimum Standard were similar to its calculation of the Preliminary 2017 Compliance Obligation and Minimum Standard (detailed here), but used 825 MW as the capacity that it expects would have been in operation had the SREC-II Program Capacity Cap not been expanded. The DOER used the 825 MW value to reflect its estimate of the generation facilities that would be qualified and operational by the end of the year – a significant reduction from the original 947 MW projection.

Using the 825 MW estimate, the DOER determined a total baseline Compliance Obligation of 969,635 MWhs and a Minimum Standard of 2.0197%. These two figures are significantly less than their counterparts from the preliminary 2017 Compliance Obligation and Minimum Standard, which were 1,102,311 MWhs and 2.2960%, respectively.

SREC-II Obligation Chart

The latest Solar Carve-Out II Qualified Units report (updated on August 25) identified nearly 575 MW of capacity as qualified and operational under the SREC-II program. Comparing the 825 MW figure that the DOER is targeting to the existing 575 MW, the market would need to more than double the Last Twelve Months (LTM) monthly average build-rate (30 MW) to reach that threshold.

For more information on the July announcement of the Preliminary 2017 Compliance Obligation, please visit our blog post on the topic.

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MA DPU Establishes Net Metering “Notification Date” as September 26, 2016

Posted August 3rd, 2016 by SRECTrade.

On July 29, 2016, the Massachusetts Department of Public Utilities (the “DPU”) issued its Order Announcing Notification Date and Directives to Distribution Companies in its proceeding under 16-64-D, establishing the Net Metering “Notification Date” as September 26, 2016. Pursuant to Chapter 75 of the Acts of 2016, D.P.U. 16-64-C, and as confirmed by this Order, there are three strict criteria that must be met for a private net metering project to receive net metering credits under the old regime:

  1. Submission of an Application for Cap Allocation (ACA) to the Massachusetts System of Assurance of Net Metering Eligibility (System of Assurance) for a net metering cap allocation prior to the Notification Date of September 26, 2016 by 2:00pm;
  2. Receipt of confirmation from the System of Assurance Administrator that the application (ACA) is complete; and
  3. Receipt of a ACA cap allocation by January 8, 2017.

In its Order, the DPU determined that “the best option to result in a smooth transition to a stable and equitable solar net metering market” was to align the timing for transition to the new net metering credits policy with the Massachusetts Department of Energy Resources (DOER)’s SREC-II program. In selecting September 26, 2016 as the “Notification Date”, the DPU calculated the maximum amount of time that could be required to obtain a cap allocation on or before January 8, 2017, which was determined to be 70 business days. In addition, the September 26 date is exactly 60 calendar days after the Order’s announcement of the Notification Date. In consideration of these two timelines, the DPU determined that this date would provide enough time for systems to plan for, apply for, and receive a net metering cap allocation under the existing framework.

For more information on the current and new net metering regulation in the state of Massachusetts, please visit our previous blog post on the topic.

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MA DOER Announces Solar Credit Clearinghouse Auction Results

Posted July 29th, 2016 by SRECTrade.

Today, the Massachusetts Department of Energy Resources (DOER) announced that both of the 2015 Solar Carve-out (SREC-I) and Solar Carve-out II (SREC-II) auctions have fully cleared in the first round.

Preliminary results for the SREC-I auction included 41 unique bidders submitting a total bid volume of 49,886 – more than sufficient demand to clear the available auction volume of 1,898 SRECs. Similarly, the results for the SREC-II auction included 9 unique bidders submitting a total bid volume of 112,252, which cleared the available auction volume of 67,046 SREC-IIs.

SCCA Auction Results3

The DOER and EnerNOC continue to certify and finalize the auction results, and will publicize more details on the final results on the SREC-I and SREC-II auction webpages next week.

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MA DOER Announces Preliminary 2017 Compliance Obligation

Posted July 25th, 2016 by SRECTrade.

Friday, July 22, 2016, the Massachusetts Department of Energy Resources (DOER) announced the preliminary 2017 Solar Carve-out (SREC-I) and Solar Carve-out II (SREC-II) Compliance Obligations and Minimum Standards. Customarily, the DOER estimates these values prior to administering the Solar Credit Clearinghouse Auction each year. The final 2017 Minimum Standards will be announced on or before August 30th, after both the SREC-I and SREC-II Auctions have concluded.

Solar Carve-out (SREC-I)

Notably, the DOER projects that the final 2017 Compliance Obligation for the SREC-I program will be approximately 783,181 MWhs and that the Minimum Standard will be approximately 1.6313%. These values will be increased to 785,077 MWhs and 1.6352%, respectively, if the SREC-I auction does not fully clear in the first two rounds. The 2017 Minimum Standard for load under contracts signed before June 28, 2013 will be 0.9861%.

The DOER published a resource outlining its calculation of the preliminary SREC-I Minimum Standard.

Preliminary 2017 Compliance Obligation SREC-I Table

Solar Carve-out II (SREC-II)

Regarding the SREC-II Program, the DOER established a baseline Compliance Obligation and Minimum Standard that would have applied to Retail Electricity Suppliers had the RPS Class I Emergency Regulation not been filed on April 8, 2016; these suppliers are exempt from any additional obligations resulting from the expansion of the SREC-II Program Capacity Cap.

To calculate this baseline Minimum Standard, the DOER first determined the expected MWh/year that would have resulted had the SREC-II Program Capacity Cap remained 947 MW by:

  1. Identifying the percentage shares of MW currently qualified under each SREC-II Market Sector;
  2. Multiplying these percentages by the original 947 MW SREC-II Program Capacity Cap;
  3. Multiplying these totals by (1) their respective SREC Factors, (2) a 13.51% expected capacity factor, and (3) 8,760 hours/year.

The DOER then summed these values and combined the auction volume and banked SREC-II volume from the 2015 Compliance Filings, resulting in a baseline Compliance Obligation of 1,102,311 MWhs and a Minimum Standard of 2.2960%. These values will be increased to 1,169,357 MWhs and 2.4357%, respectively, if the SREC-II auction does not fully clear in the first two rounds.

Preliminary 2017 Compliance Obligation SREC-II Table 2

Additionally, the DOER calculated the preliminary 2017 SREC-II Compliance Obligation and Minimum Standard for load under contracts signed after May 8, 2016 – 1,496,188 MWhs and 3.1164%, respectively. These values will be increased to 1,563,234 MWhs and 3.2561% if the SREC-II auction does not fully clear in the first two rounds.

Preliminary 2017 Compliance Obligation SREC-II Table

The DOER also published a resource outlining its calculation of the preliminary SREC-II Minimum Standard.

Solar Credit Clearinghouse Auctions

The first rounds of the SREC-I and SREC-II Solar Credit Clearinghouse Auctions are scheduled for July 29, 2016. A second and third round will be held as needed the following week should these auctions not fully clear.

The DOER has also provided slight updates to the volumes of SRECs available in the Auctions: 1,896 in SREC-I and 67,046 in SREC-II.

SRECTrade will continue to monitor the proceedings of the Solar Credit Clearinghouse Auctions and will report the outcomes of the Auctions once the results become readily available.

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MA Department of Public Utilities Clarifies Net Metering Regulation

Posted May 25th, 2016 by SRECTrade.

Please note this blog post has been revised from the original May 24, 2016 post.

On Wednesday, May 18th, the Massachusetts Department of Energy Resources (DOER) notified the Department of Public Utilities (DPU) of its intent to file its determination that the 1,600 Megawatt (MW) threshold will be met on or about June 1, 2016 and requested that the DPU clarify whether facilities with private cap allocations on or before the “Notification Date” will receive the current net metering credits or the new Market Net Metering Credits. Under the recently enacted Chapter 75 of the Acts of 2016, this determination sets into motion DPU’s charge to establish a “Notification Date”, which will serve as a deadline for systems that are under the private net metering cap to be interconnected or allocated under the cap in order to receive the current net metering credits. Furthermore, the DOER requested that the DPU clarify its Emergency Net Metering Regulations and assure those facilities in receipt of net metering cap allocations on or before the Notification Date that their projects will receive net metering credits at current rates and will not receive Market Net Metering Credits (which are effectively equal to 60 percent of the retail rate). Prior to the DOER’s request, the uncertainty around the Notification Date deadline left private-cap projects in advanced stages of construction at risk of receiving Market Net Metering Credits if they failed to be interconnected by the Notification Date, creating project financing concerns.

In its May 19th Order Clarifying Emergency Net Metering Regulations, the DPU formally recognized that systems obtaining a private net metering cap allocation are “on the path toward interconnection”, since these allocations are assurances that a system will receive net metering services upon authorization to interconnect. In clarifying its policy on net metering credit eligibility, the DPU extended retail rate credit eligibility for projects that receive a private cap allocation by the Notification Date, even if those projects are not yet interconnected. Resultantly, for the duration of the Emergency Net Metering Regulations, Solar Net Metering Facilities that are interconnected or in receipt of a private cap allocation from the System of Assurance by the Notification Date shall receive retail rate net metering credits (that is, Net Metering Credits as defined in 220 C.M.R. § 18.04(1) and (5)).

This interpretation of eligibility will remain in effect only for the effective period of the Emergency Net Metering Regulations, and it is highly probable that the Notification Deadline will be set by the DPU for a date later than June 1, 2016. Following notice by the DOER that the 1,600 MW cap has been allocated, the DPU will solicit comments on the Emergency Net Metering Regulations and related issues, conduct a public hearing, and enact Final Net Metering Regulations effective July 29, 2016. Accordingly, it is possible that the Notification Deadline will be set as July 29, 2016 or possibly later than this date.

In accordance with the Order, facilities under the private net metering cap that fail to meet the Notification Date deadline will receive Market Net Metering Credits. Residential projects 10 kW and smaller on single-phase circuits, or systems under 25 kW on 3-phase circuits, will be exempt from the new rate structure under Sections 7 and 8 of the Act and are guaranteed retail remuneration rates. To be clear, facilities under the public net metering cap will continue to receive net metering credits at the current rates and will not be impacted by this Notification Deadline. For more information on current net metering and other solar legislation in Massachusetts, please visit our previous blog post on the topic here.

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