Posts Tagged ‘Mark Sylvia’

DOER Commissioner Mark Sylvia’s SREC-II Preview

Posted December 20th, 2013 by SRECTrade.

The Massachusetts SREC market is in the process of switching from the existing SREC-I program to a yet to be officially proposed SREC-II program.  At a meeting held on Friday, 12/13/2013, Mark Sylvia, the Commissioner of the Massachusetts Department of Energy Resources (DOER),  presented a preview of some items we should expect to find in the DOER’s official SREC-II proposal.

In August 2013, the DOER  presented a draft proposal for the SREC-II program with the intention to incorporate feedback from stakeholder groups before presenting a final proposal sometime by the end of 2013. Now that 2013 is nearly done, it’s likely that the formal proposal will not emerge until early January 2014. Once the SREC-II proposal is issued there are several regulatory hoops that the proposal must go through before the program can be put in place. We blogged about the SREC-II implementation timeline in a previous post here and expect the process to take 100 days or more.

Key items learned from Mark Sylvia’s presentation

Items that have not changed from the draft proposal

1) SREC factors and Market Sectors – Depending on project size and other considerations projects will be able to produce SRECs at different rates. Smaller projects receive more SRECs on a per MW-hr basis than larger projects. For example, a residential project will receive 1 SREC for every MW-hr produced, whereas a landfill sited project might receive 0.8 SRECs per MW-hr. SREC factor will be determined by Market Sectors as described below.

Market Sectors

2) Declining Solar Credit Clearinghouse Auction (SCCA) pricing and Alternative Compliance Payment (ACP) rates – The SCCA is the MA market’s price floor mechanism. In SREC-I the SCCA is fixed at a price of $300/SREC, but the SCCA will drop from $300 to $285 starting in 2017 and then drop again on a yearly basis with SREC-II. The SREC-II ACP rate will start at $375 in 2014 and 2015 and decline, beginning in 2016, as shown in the table below.

ACP Schedule

Items that HAVE changed from the draft proposal

1) No Forward SREC Minting
Originally the DOER proposed that residential projects should be eligible to create 10 years worth of SRECs  at the onset of a project. This provision was removed, presumably amid concerns about how to properly track and incentivize SREC production after the upfront issuance and payment is made.
2) No Competitive SREC Factor 
All projects are to be assigned fixed SREC factors determined by Market Sector. In the DOER’s draft proposal, projects under the Managed Growth Market Sector (>500 kW and less than 67% on site electricity usage) would competitively offer for a spot to be eligible for the SREC-II program by adjusting the SREC factor. Projects with the lowest SREC factors would be given a spot in the eligible projects queue. This is no longer the case.
3) New Grant Program for Directly Owned Residential Facilities 
The Commonwealth Solar II grant program will stay in place until another $30 million program can be implemented using Alternative Compliance Payment (ACP) funds to support direct ownership. Presumably 3rd party leasing / PPA entities will not be able utilize the funds. It was previously expected that the current grant program would end with the sunset of SREC-I.
How Much Longer?
In-line with our expectations, the presentation announced the RPS revisions for SREC-II should be filed any day. A public hearing and comment period will follow as well as committee review processes. The DOER projects that the rules will become effective by the end of Q1 2014. We will continue to keep a close eye on the rule making process and provide updates as they are available.