Posts Tagged ‘Massachusetts Solar Carve-out’

Massachusetts Governor Baker Releases Net Metering Bill to Rival Senate Bill

Posted August 13th, 2015 by SRECTrade.

Shortly before its summer recess, the Massachusetts Senate passed Amendment 18 to S. 1973 in a voice vote on July 23. Two weeks later, on August 7, 2015, Massachusetts Governor Charlie Baker released a net metering bill to rival S. 1973.

Both the Senate Bill and the Governor’s Bill address the net metering caps that are currently causing a slow-down in the Commonwealth’s solar development, and look to former Governor Patrick’s goal for the Commonwealth to install 1,600 megawatts of solar energy in Massachusetts by 2020. Earlier this year, the Baker-Polito Administration announced its support of the goal to achieve 1,600 MW by 2020. Accordingly, both S. 1973 and the Governor’s Bill propose to raise the net metering caps to meet the goal of 1,600 MW by 2020.

Under Amendment 18 to S. 1973, the Senate calls for raising the caps to 1,600 MW, and eliminating the caps thereafter (the elimination of the caps would apply to solar net metering facilities, with the exception that the maximum amount of generating capacity eligible for net metering by a municipality or other governmental entity shall be 10 megawatts), but the bill would do little else to change the value of a net metering credit. In addition to addressing the caps, the Amendment calls for Massachusetts regulators to “develop a solar incentive program to encourage continued development of solar…” with the goal of “develop[ing] a sustainable long-term framework that effectively balances promoting clean energy and costs to ratepayers,” to be implemented after the 1,600 MW target has been reached. Unfortunately, the Senate bill also attempts to limit the potential options for future programs, without much consideration for allowing the stakeholder process to consider all of the policy options presented by the Task Force in its Final Report (see below).

In contrast, Governor Baker’s Bill would substantially reduce the value of net metering credits in the Commonwealth. For solar projects over 10 kW on single phase, or projects over 25 kW on 3-phase, the value of net metering credits will be the average monthly clearing price in ISO-NE (that is, the wholesale retail rate). This would be a drastic change from the current value, which includes the value of all wires charges, such as distribution, transmission and transition charges. For other specific facilities, including municipal or other governmental entity (“MOOGE”) facilities, facilities for low-income off-takers and community shared solar facilities, the value of net metering credits will be based on the utility’s basic service kW charge, and will also exclude wires charges. The result of this exclusion in both categories is the value of credits being cut nearly in half. But like the Senate Bill, the Governor’s Bill also calls on Massachusetts regulators to “establish a solar incentive program for the development of distributed solar generation beyond 1,600 [MW] by solar photovoltaic facilities connected to a distribution or transmission system, which shall be a statewide program.”

Both the Senate Bill and the Governor’s Bill draw upon the recommendations from the Net Metering and Solar Task Force. The Net Metering and Solar Task Force was a group established last fall by the Massachusetts Legislature under Ch. 251 of the Acts of 2014, Section 7. The Task Force was responsible for reviewing the “long-term viability of net metering and develop recommendations on incentives and programs to support the deployment of 1600 MW of solar generation facilities in the commonwealth.” In its Final Report, the Task Force encouraged the Commonwealth to develop a solar incentive framework that would satisfy eight different program attributes, including promoting the orderly transition to a stable, equitable and self-sustaining solar market, and relying on market-based mechanisms and/or price signals as much as possible to set incentive levels such that the program would be readily adaptable to changing market conditions, all while minimizing costs, incentivizing diverse development, and promoting investor confidence. The Task Force cautiously qualified its recommendations by stating that “[t]he selection of a path for modeling is not an indication that a majority, or indeed any, of the Task Force members would like to see that path implemented,” and encouraged the DOER and DPU to lead a “comprehensive and transparent solar benefit/cost study to determine the value of impact of solar in Massachusetts” so that the Massachusetts Legislature, DOER, and DPU could more thoroughly evaluate the options presented by the Task Force, including the potential for an SREC III program to follow the highly successful SREC I and SREC II programs.

When the Legislature returns from its summer recess this Fall, the Joint Committee on Telecommunications, Utility and Energy will be confronted with the formidable task of reconciling these rival bills alongside the recommendations from the Net Metering and Solar Task Force, in order to help shape the future of solar in Massachusetts.

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 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 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.

Update regarding Massachusetts DOER Solar Credit Clearinghouse Auction

Posted December 17th, 2012 by SRECTrade.

Earlier this month SRECTrade hosted a webinar on the Massachusetts SREC market. Since then, there have been a few questions relating to the Massachusetts DOER’s Solar Credit Clearinghouse Auction, informally referred to as the “Last Chance Auction.” Since there is a confirmed oversupply in Massachusetts for 2012, the Solar Credit Clearinghouse Auction will occur in July of 2013 for all unsold SRECs. The auction was designed as a “price support mechanism” for the Massachusetts SREC market, but it does not represent a “price floor,” a common misperception.

The specific dates of the auction are yet to be determined, but here is a rough outline of the timeline:

  • May 15th: Sellers may begin to deposit unsold SRECs int he Auction Account
  • June 15th: Deadline for sellers to deposit their unsold SRECs in the Auction Account (SRECTrade does this automatically for our customers)
  • Late June: Webinars, FAQs, Q&As will all be provided
  • July: Auction is held
  • August: Payments are made sometime in August
  • August 15th: Entire auction process (excluding payment delivery) must be completed by this date in order to commence 2013 SREC market activity

Here are a few key things to know about the auction:

  • All unsold SRECs must be deposited in the Solar Credit Clearinghouse Auction, otherwise they are forfeited by the seller and retired, having no value to the sellers (again, SRECTrade will ensure that every unsold SREC is deposited for our clients)
  • SRECs must be deposited in the auction by the original aggregator/account holder. 3rd party account holders are ineligible from participating in the Solar Credit Clearinghouse Auction
  • If the auction clears, sellers receive $285 per SREC (note: SRECTrade fees are applicable)
  • If the auction does not fully clear, every seller will sell an equal percentage of SRECs. If 50% of the auction clears, each seller will sell 50% of the SRECs deposited
  • SRECs that do not clear in the auction are returned to the seller with 3 additional years of life, so the SREC created in 2012 will have value to a buyer in 2013, 2014 and 2015
  • SRECs that do not clear in the auction are NOT eligible for any future Solar Credit Clearinghouse Auctions
  • If there is an oversupply, Buyers may “bank” up to 10% of their 2012 requirement and use them in 2013 or 2014

Here is the full webinar from December 5th, 2012:

MA DOER Releases 2012 SREC Requirement

Posted September 5th, 2011 by SRECTrade.

The Massachusetts Department of Energy Resources (DOER) recently announced the SREC requirement for the 2012 compliance year. The 2012 compliance requirement is based on a formula that takes into consideration the 2011 compliance obligation, the forecast 2011 total SREC generation, and the actual 2010 SREC generation. A growth rate is then applied to these figures based on a set formula for the MA SREC program. Additional considerations are made for the 2010 Alternative Compliance Payment (ACP) volume, the 2010 banked SREC volume, and the number of 2010 SRECs purchased through Solar Credit Clearinghouse Auction. For a detailed analysis of this formula and the considerations made for setting the 2012 requirement please see this link.

Upon running the figures, the DOER arrived at a 2012 compliance obligation of 81,559 MWhs or SRECs. This represents an increase over the 2011 standard by 2,982 SRECs, or approximately 3.8%. After factoring in the estimated load exemptions from the TransCanada settlement, the 2012 compliance year target is approximately 73,400 SRECs. This equals an increase of approximately 10,400 SRECs from the 2011 adjusted target of about 63,000 SRECs. Converting these figures to MW capacity, using a 1.13 MWh production factor per installed kW per year, 2012 will need the equivalent of approximately 65 MW online vs. the 2011 required capacity of approximately 55.7 MW. This step up in capacity represents an increase of 16.6%.

MA 2012 Capacity Req Graph

*Note: The 2011 and 2012 estimated megawatts required in the chart above have been adjusted for the impact of the TransCanada settlement.


Posted August 16th, 2011 by SRECTrade.

The Massachusetts DOER has revised their application schedule by moving up the deadlines for generation eligibility. The new schedule states that in order for systems generating electricity prior to June 30th (Q2) to get SREC credit for that generation, their applications must have been submitted by August 15th, though there is expected to be some leniency around this first deadline. We strongly urge all unregistered MA customers to submit their EasyREC applications AS SOON AS POSSIBLE (i.e. the next few days) if their systems were generating prior to June 30th. Future deadlines are listed below.

Q2 generation (systems online before June 30th): must apply by 8/15/11

Q3 generation (system online before September 30th): must apply by 11/15/11

Q4 generation (system online before December 31st): must apply by 2/15/12

Please email your completed MA EasyREC application to or fax to (732) 453-0065.

MA DOER Seeks to Set Fixed SACP Schedule

Posted August 3rd, 2011 by SRECTrade.

On August 2, 2011, the Massachusetts Department of Energy Resources (DOER) proposed an amendment to the Solar Alternative Compliance Payment (SACP) schedule for the MA SREC program. Feedback from market participants including project developers, financing parties, and retail electricity suppliers indicated the current SACP structure creates uncertainty around future SREC valuation. Under the existing structure, the DOER has the ability to reduce the SACP on a yearly basis by up to 10% of the current value. The amended schedule seeks to provide more certainty for expected future prices while assisting project financing and negotiations for long-term SREC contracts.

The proposal establishes a 10-year schedule for the SACP that would maintain the current rate of $550/SREC through compliance year 2013, then decrease 5% each following year. The proposal also requires the schedule to be updated on a yearly basis to include a price for the 10th year of the schedule. For example, the 2022 price will be added to the schedule no later than January 31, 2012. The table below demonstrates the proposed schedule.

MA SACP Schedule 8_2_11

Prior to implementation, the proposed schedule is to go through a comment process. The comment period is currently open through August 15, 2011. Once all comments are collected, the DOER will review and begin the necessary process to amend the existing Solar Carve-Out provisions.

Mass DOER releases July statistics, SRECTrade continues to lead in Mass SREC market

Posted July 20th, 2011 by SRECTrade.

With the August SREC auction coming next Friday, July 29th, SRECTrade will post the first sale for 2011 SRECs in Massachusetts. Last week, the DOER released the most recently updated list of qualified and installed solar projects (excel download) in the state that are eligible for the solar carve-out. This gives us a unique opportunity to look behind the curtains and see what is going on in the SREC market.

Of the 649 projects that are operational, SRECTrade’s aggregation is by far the largest in the state, representing 36% of all facilities that are operational in Massachusetts. In terms of installed capacity, with nearly 3 MW of 19 MW installed as of July 11, the 16% share of capacity is second only to the state’s largest utility, National Grid who has installed 4 projects totaling 3.4 MW which represents 18% of the solar capacity in the market. That said, 16% understates SRECTrade’s presence in the Massachusetts since signing up for SRECTrade’s aggregation service is not a pre-requisite for selling through the platform.

Largest SREC Aggregations in Massachusetts

% of

Capacity Rank

% of

Facility Rank

National Grid










Totals: 649 Facilities / 19.0 MW

Although key features like transparent, competitive market pricing, low fees, no contracts to sign and online access to the SRECs that are not lumped together with other facilities have made SRECTrade an attractive option to solar owners, the success of the platform can ultimately be attributed to the network of installers that recommend it to their customers. According to the DOER’s report, 42 of the 111 installers with facilities in the ground have customers with SRECTrade, including 8 of the top 10 installers by volume.

Top Installers In SRECTrade’s Network as of July 11, 2011 (as published by DOER)
– My Generation Energy, Inc., Brewster, MA
– SunBug Solar, Somerville, MA
– Sunlight Solar Energy, Waltham, MA
– E2 Solar Inc., Hyannis, MA
– Alteris Renewables Inc., Natick, MA
– NorthEast Solar Design Associates, West Hatfield, MA
– South Mountain Company, Inc., West Tisbury, MA
– SolarFlair Energy, Inc., Framingham, MA

The SRECTrade aggregation is not a prerequisite to participate in the SRECTrade market. The platform is open to anyone in the market looking to sell SRECs. The improved fee structure makes SRECTrade a simple and inexpensive option for aggregations with SRECs to sell. The combination of an open platform and guaranteed volume coming from the state’s largest aggregation makes SRECTrade the top destination in Massachusetts for entities with compliance obligations.

MA DOER Updates Retroactive SREC Rules

Posted June 1st, 2011 by SRECTrade.

The DOER announced today that they will no longer be awarding retroactive credit for SRECs from generation prior to the current SREC generation period.

In simplified form, this change means that installers and system owners should get their EasyREC paperwork in as soon as their system is interconnected to the electric grid. By submitting immediately, the the DOER and MassCEC will have ample time to approve the system. Even for systems that go online at the end of Q1 (i.e. March 20th), the state will then have a full 3 months to get the system certified for Q1 SRECs on July 15th.

If a system was interconnected in Q1 but is not certified in DOER by July, then it’s first chance to create SRECs will be October 15th. On that date, DOER will only create Q2 SRECs, and will ignore any Q1 SRECs that would have been generated for the system on July 15th.

All recent applications to SRECTrade’s EasyREC service have already been submitted to DOER on the customer’s behalf, and thus are not going to be affected by this change. Feel free to follow up with us, though, if you would like to double-check your status.

If your system went online before March 31, 2011 and you have not yet submitted your application, go to our EasyREC page and fill out the forms as soon as possible!

How long will projects be eligible for the Massachusetts Solar Carve-Out?

Posted March 16th, 2011 by SRECTrade.

Understanding the length of time that Massachusetts solar facilities can generate and sell SRECs as part of the Solar Carve-Out is key to financing solar in the state. In an earlier post, we explained the Massachusetts Last-Chance Auction in great detail. The purpose was to help stakeholders understand the conditions, if any, that would result in the SREC market dropping below $285. From there, it is also important to understand how long a facility can bank on the floor price set by the auction.

The Opt-In Term is the length of time a facility is eligible for the Last-Chance Auction
There are a few misconceptions regarding the “10-year” Opt-In Term and the 400 MW Minimum Standard Cap. For example, it might seem that the program is slated to last 10 years or until it reaches 400 MW, after which the SRECs go away. This is most definitely NOT true. The Opt-In Term actually represents the length of time that a facility that is approved for the SREC program can opt into the Last-Chance Auction, i.e. the amount of time a facility is guaranteed a floor price in the market. Once a facility is approved, this term cannot be changed – though the Opt-In Term for future projects may be adjusted by the DOER (see below).

The 400 MW Cap is a limit to the amount that will be approved for the Solar Carve-Out
Meanwhile, the 400 MW cap is actually just a limit to the capacity of projects that can be eligible for the Solar Carve-Out. The 400th MW approved for the SREC program will be eligible for the full-length of the published Opt-In Term. This means that if Massachusetts reaches 400 MW in 2015 and the Opt-In Term is still 10 years, then the Solar Carve-Out will fade out in 2025. In simple terms: the state will accept 400 MWs into the program and every accepted facility will be guaranteed a floor of $285 for “X years” from the time it is installed. “X years” will vary based on the Opt-In Term established in the year of installation.

The Opt-In Term may change for future projects
Today, the Opt-In Term is 10 years and that will not change for any existing projects. However, every year, the DOER may make a change to the Opt-In Term for NEW facilities based on the results of the last-chance auction. If there is an oversupply, then the Opt-In Term may be decreased by as much as 2 years to a minimum of 5 until 2017, and a minimum of zero thereafter. If there is a shortage, the Opt-In Term may be increased to a maximum of 10 years.

The Solar Carve-Out expires when the Opt-In Term ends for the final project approved under the 400 MW Cap
Finally, facilities can continue to sell SRECs after the Opt-In Term as long as the Solar Carve-Out program is still in place. The only difference is that those facilities will no longer be eligible for the Last-Chance Auction and therefore are not supported by the $285 floor price. The Solar Carve-Out will expire after the Opt-In Term for the final project registered under the 400 MW Cap has concluded AND all remaining SRECs created during that time have either been sold or expired. After this time, all facilities will be transferred to the RPS Class I REC market (which by that time could be worth very little).

Here are the key paragraphs taken from the DOER Solar Carve Out website worth reading carefully:

Minimum Standard Cap and Termination of the Program
The Minimum Standard is capped at 455,520 MWh (sufficient to enable the installation of approximately 400 MW of solar PV). When DOER qualifies 400 MW of solar for the program, qualification of all additional solar installations is transferred to the RPS Class I Program. Once the cap has been met, the Minimum Standard for the RPS Solar Carve-Out will be set annually per regulation to maintain market balance. The RPS Solar Carve-Out program remains in effect until all the Auction Opt-In Terms of the qualified projects and the full shelf-life years of any Re-Minted Auction SRECs have both expired, thereby maintaining the price certainty promised to all solar generators. For the year after the final Compliance Year, when the Solar Carve-Out Minimum Standard is set to zero SRECs shall cease to exist, and all generation from qualified Solar Carve-Out Renewable Generation Units shall produce RPS Class I Renewable Energy Attributes.

Opt-In Term
The Auction Opt-­In Term is defined as the number of years (expressed in calendar quarters) that a project is eligible to deposit SRECs into the Solar Credit Clearinghouse Auction Account. For all projects qualified in 2010, this is set at 10 years, or 40 quarters. Any SRECs generated in this span of 40 quarters will be eligible to participate in an auction that will potentially be held each July, where they will be assured a price of $300/MWh for their SRECs (minus a $15 auction fee assessed by DOER). This mechanism sets a floor price for SRECs and gives projects long-­term price assurance should they be unable to sell them directly to LSEs or there be an oversupply of SRECs. Once a project’s Opt-In Term has expired, its owner may continue to sell their SRECs until the program officially ends, but will not have the price assurance guaranteed by the ability to Opt-­In to the auction.

Adjustments to Auction Opt-In Term
Long Market (SREC Oversupply) Adjustment: The Auction Opt-In Term is reduced by 4 quarters for each full 10% of the year’s Compliance Obligation that is deposited into the Auction Account. The maximum reduction per annual adjustment is two years. The minimum Auction Opt-In Term is 20 quarters or 5 years for the first 7 years of the program (through Compliance Year 2016). After that time, the minimum term is reduced to zero years, unless otherwise set by the Department of Energy Resources (DOER). Short Market (SREC Shortage) Adjustment: The Auction Opt-In Term is increased by 4 quarters for each full 10% of the year’s Compliance Obligation that is met through Alternative Compliance Payments. The maximum reduction per annual adjustment is two years. The maximum Opt-In Term is 40 quarters.

In conclusion, we will monitor the Opt-In Term as it is published each year by the DOER. The term will not change for existing projects once established, but it will impact new projects. Solar developers should consider this as they do project finance for facilities that may not be completed this year. Given the shortage in the SREC market in 2010, we do not foresee any changes to the Opt-In Term in 2011.

SRECTrade continues to offer long-term Fixed-Price and Upfront SREC payments for solar projects in Massachusetts.