Archive for January, 2014

MA DOER Hosts Public Hearing on SREC-II Program

Posted January 28th, 2014 by SRECTrade.

On Friday, January 24, the Massachusetts Department of Energy Resources (MA DOER) held a public hearing in Boston. The meeting allowed MA solar stakeholders to provide feedback and comments on the proposed SREC-II regulations. Additionally, the DOER will be accepting written comments on the SREC-II legislation. All written comments are due by this Wednesday, January 29th at 5 p.m. ET. Comments can be submitted electronically to DOER.SREC@state.ma.us or to Michael Judge, via mail to the Department of Energy Resources, 100 Cambridge Street, Suite 1020, Boston, MA 02114.

For an overview of the draft regulations, see our blog post here: DOER Releases Draft of SREC-II Regulations. As it currently stands, it appears the SREC-II program will be put in place as early as the beginning of Q2 2014. We’ll continue to provide more information on the development and implementation of the program as it becomes available.

SRECTrade Markets Report: December 2013

Posted January 21st, 2014 by SRECTrade.

The following post is a monthly update outlining the megawatts of solar capacity certified to create SRECs in the Solar REC markets that SRECTrade serves. All PJM data is based on the information available in PJM GATS as of the date noted. All MA data is based on the information provided by the DOER as of the date noted. This analysis does not include projects that are not yet registered and certified with the entities noted herein.

A PDF copy of this table can be found here.

2013-12_Capacity Report_Updated_2014-01-22-REVISED

Overview of PJM Eligible Systems

As of January 7, 2014 there were 40,238 solar PV and 798 solar thermal systems registered and eligible to create SRECs in the PJM Generation Attribute Tracking System (GATS). Of these, 265 (up 8 projects since November and representing 0.65% of the total projects installed) have a nameplate capacity of 1 megawatt or greater, but account for 43.1% of the overall capacity registered. Twenty-nine of these projects have a nameplate capacity of 5 MW or greater (an increase of 1 project since our last update). New Jersey continues to host most of the larger scale facilities, claiming home to 18 of the 29 facilities, that are equal to or greater than 5 MW. The big change is a 19.9 MW project interconnected in November 2012 was recently registered in GATS, causing a large bump in the NJ qualified capacity. The three largest projects are a 29.1 MW project in MD, followed by a 25.1 MW and the new 19.9 MW project, both registered in NJ.

NJ Office of Clean Energy Estimated Installed Capacity Through 12/31/13

On January 14, 2014, the New Jersey Office of Clean Energy (OCE) announced total installed solar capacity reached 1,184.5 MW; an increase of approximately 16.4 MW over the total capacity reported at the end of November. However, the average last six month build rate per month, according to the OCE data, is steady at 11.7 MW. Note that this data does not directly tie to GATS registration data because of a lag between NJ Office of Clean Energy certifications and GATS registrations.

Overview of MA DOER Eligible Systems

As of January 21, 2014, there were 9,895 MA DOER qualified solar projects; 9,714 operational and 181 not operational. Total qualified capacity is 672.3 MW (a decrease of 22.3 MW* since our last monthly capacity report); 410.0 MW of which is operational (up 74.2 MW from the DOER’s December 20, 2013 report) and 262.3 MW of qualified capacity is not yet operational under the current SREC-I program.

*Not operational, qualified projects over 100 kW in size were required to demonstrate that at least 50% of the project’s costs be incurred by 12/31/2013 in order to remain qualified. The latest DOER Solar Carve Out report suggests that at least 22.3 MW of capacity was removed from eligibility for failing to meet the requirements of this deadline. Projects less than 100 kW must be interconnected by the effective date of the SREC-II program or June 30, 2014, whichever is earlier. Whereas projects greater 100 kW in capacity must have submitted application paperwork and met certain requirements by July 5, 2013. For more information refer to our blog posts covering the current SREC program.

How to Interpret This Table

The tables above demonstrate the capacity breakout by state. Note, that for all PJM GATS registered projects, each state includes all projects certified to sell into that state. State RPS programs that allow for systems sited in other states to participate have been broken up by systems sited in-state and out-of-state. Additional detail has been provided to demonstrate the total capacity of systems only certified for one specific state market versus being certified for multiple state markets. For example, PA includes projects only certified to sell into the PA SREC market, broken out by in-state and out-of-state systems, as well as projects that are also certified to sell into PA and Other State markets broken out by in state and out of state systems (i.e. OH, DC, MD, DE, NJ). PA Out-of-State includes systems sited in states with their own state SREC market (i.e. DE) as well as systems sited in states that have no SREC market (i.e. VA). Also, it is important to note that the Current Capacity represents the total megawatts eligible to produce and sell SRECs as of the noted date, while the Estimated Required Capacity – Current and Next Reporting Year represents the estimated number of MW that need to be online on average throughout the reporting period to meet the RPS requirement within each state with only that particular compliance period vintage. For example, New Jersey needed approximately 496.7 MW online for the entire 2013 reporting year to meet the RPS requirement with 2013 vintage SRECs only. SRECs still available from prior eligible periods can also impact the Solar RPS requirements. Additionally, the data presented above does not include projects that are in the pipeline or currently going through the registration process in each state program. This data represents specifically the projects that have been approved for the corresponding state SREC markets as of the dates noted.

Note: SREC requirements for markets without fixed SREC targets have been forecast based on EIA Report “Retail Sales of Electricity by State by Provider” updated 10/1/12. Projected SRECs required utilizes the most recent EIA electricity data applying an average 1.5% growth rate per forecast year. The state’s RPS Solar requirement is then multiplied by forecast total electricity sales to arrive at projected SRECs required. Projected capacity required is based on a factor of 1,200 MWh in PJM states and 1,130 MWh in MA, generated per MW of installed capacity per year.

New Jersey SREC Market Update: Prices Are Up

Posted January 21st, 2014 by SRECTrade.

Prices for New Jersey SRECs have increased dramatically over the last month from the $140s in early December to current pricing in the low $170s. The RY2014 vintage cleared in our December auction at $138.01 and the January auction just cleared $169 for the same product, but recent over-the-counter deals have been done in the $170s.

NJ 2014 Pricing Over Time 520

Why are  NJ RY2014 SRECs trading higher?

In recent months, the monthly build-rate for new solar projects has been relatively restricted and significantly lower than build rates seen in RY2013. The average for the last six months (LSM) is 11.7 MW per month, while the last 12 months (LTM) is 16.9 MW. Lower build rates, mean fewer SRECs than expected, which in turn causes both sellers and buyers to be more aggressive in how they price the market. However, the market remains fundamentally over-supplied in RY2014 when taking into consideration unretired eligible SRECs from previous reporting years and SRECs minted from RY2014 generation.

Workbook1 Sheet1

Impact of Basic Generation Service Procurement on SREC Prices

Another reason that may explain the run-up in prices and volumes-traded is the forthcoming Basic Generation Service (BGS) electricity procurement.

Each year, in early February, the regulated electricity utilities in New Jersey conduct an auction in which wholesale power providers compete to provide Basic Generation Service to consumers in New Jersey. In providing electricity, the wholesale power suppliers must also provide the requisite SRECs corresponding to the electricity load. In short, during the BGS auction period, there is a significant increase in market activity. This alone warrants attention from sellers. Coupled with recent run-up in prices, sellers should be especially poised to act.

With increased prices and increased market activity, now could be an ideal time to lock in your revenue for SREC sales. We’re here to help facilitate the transaction, so please feel free to contact us.

January 2014 Auction Results

Posted January 20th, 2014 by SRECTrade.

SRECTrade’s January 2014 SREC Auction closed on 1/15/14. Below are the clearing prices by vintage across the markets sold in the auction.

SREC Prices SREC Vintage Year
State 2011 2012 2013 2014*
Delaware $41.00
Maryland $130.00 $140.00
Massachusetts $250.00
New Jersey $160.01 $169.00 $169.00
Ohio In-State $48.00
Ohio Out-of-State $48.00 $48.00 $48.00
Pennsylvania $40.01 $42.51 $47.00
Washington, DC $480.00

Notes: *Delaware, New Jersey and Pennsylvania operate on a June-May energy year. For example, current vintage “2014” SRECs are generated beginning in June of 2013.
– reflects no sale, which would result if there were no SRECs available for sale in that vintage or there were no matching bids and offers to determine a clearing price.

State Market Observations

Delaware

DE SRECs for the June 2013 – May 2014 period transacted at $41.00/SREC. The primary buyer for DE SRECs is Delmarva Power and Light (DPL) and most SRECs are sold through DPL’s SRECDelaware program which allows SREC asset owners to submit competitive applications in order to obtain 20 year SREC contracts. There continues to be limited need for SRECs outside of DPL’s program and demand outside the procurement program is expected to decrease over time.

Maryland

MD2012s and MD2013s  transacted at $130.00 and $140.00/SREC, which was identical to the pricing posted in the December auction. Sellers may expect slightly higher demand over the next month as buyers close out their calendar year 2013 compliance requirements.

Massachusetts

2013 vintage SRECs cleared at $250.00 up from the $241.01 auction price posted during the October 2013 Q2 SREC issuance. The $250 auction price is more or less in line with recent brokered spot trades outside of the auction.

New Jersey

NJ2013 and NJ2014 SRECs transacted at $169.00/SREC, a rough increase of 25-30% from the December 2013 auction. Pricing reflects slower than expected build rates in NJ. The current last six month (LSM) average is 11.7 MW, against a last twelve month (LTM) average of 16.9 MW.

Ohio

OH sited and adjacent SRECs priced at $48/SREC in the January 2014 auction. The market remains over-supplied. Of note, for the first time OH sited SREC pricing fell in line with out-of-state OH SREC pricing likely related  to 1) the closing of the 2013 compliance year and 2) an increase in Pennsylvania SREC demand where out-of-state eligible SREC accounts are heavily cross-listed.

Pennsylvania

PA2012s, PA2013s and PA2014s traded at $40.01, $42.51 and $47.00/SREC respectively – roughly doubling December’s prices. The PA SREC market remains over-supplied, but future RPS increases and fewer lower priced offers available in the market has lead to an increase in price. 

Washington, DC

DC is an under-supplied market so highly limited volumes of older vintage SRECs are available. No SREC transactions occurred for the DC2011 and DC2012 vintages. DC2013s transacted at $480/SREC, which is 96% of the $500 SACP.

For historical auction pricing please see this link. The next SRECTrade auction for all SREC markets closes on Wednesday, February 5th at 5 p.m. ET.

DOER Releases Draft of SREC-II Regulations

Posted January 7th, 2014 by SRECTrade.

225 CMR 14.00 Renewable Portfolio Standard Class I Regulations

On January 3, 2014, the Massachusetts Department of Energy Resources (DOER) filed revisions to the 225 CMR 14.00 Renewable Portfolio Standard Class I regulation. The email announcement is available here. The redlined, unofficial version of this draft is available on the DOER website, and the official version of the draft regulation will be published in the Massachusetts Register on January 17, 2014. This filing begins the formal rulemaking process.

The primary objectives of the revisions are twofold: 1) to establish the second phase of the Solar Carve-Out program (the SREC-II program); and 2) to revise the RPS Class I program to address previously identified needs to improve the program design. Next stages for the rulemaking process and a few excerpts of the draft are detailed below.

I. Continuation of Rulemaking Process

A. Public Hearing

The DOER will hold a public hearing on January 24, 2014 from 1:00 to 3:00 pm to receive oral and written comments on the proposed regulations. The hearing will be held at the Gardner Auditorium of the Massachusetts State House in Boston, MA. Parties interested in presenting oral testimony at the hearing are requested to provide written copies of their testimony.

B. Written Comments

Per the DOER: Written comments will be accepted beginning on January 3, 2014 and ending at 5:00 pm on January 29, 2014.  Please submit written comments electronically to DOER.SREC@state.ma.us or to Michael Judge, via mail to the Department of Energy Resources, 100 Cambridge Street, Suite 1020, Boston, MA 02114.

II. Selected Excerpts

A. Eligibility for SREC-II

Section 14.05(9)(b) specifies that a Solar Carve-Out II (SREC-II) Renewable Generation Unit must have a Commercial Operation Date on or after January 1, 2012 and must not be qualified as a Solar Carve-Out Renewable Generation Unit (that is, qualified under the SREC-I program). Section 14.06(4)(c) states that the RPS Effective Date for SREC-II facilities shall be the Commercial Operation Date or the first day following the calendar quarter in which the Unit receives its Statement of Qualification (see Part C. below), whichever is earlier.

Like SREC-I facilities, SREC-II facilities will be issued 40 quarters of SREC-eligibility, based on the SREC factor times the number of MWh generated. The SREC factor assigned to a Unit in its Statement of Qualification (SQA) shall remain its SREC factor for its entire 40 quarters of eligible generation of Solar Carve-Out II Renewable Generation Attributes. Furthermore, the DOER shall complete a review of the SREC Factor Guideline no later than March 31, 2016 to take into consideration market data and analysis as well as external changes in state and federal policies and global markets. Any changes made by these guidelines shall apply to Sectors A-C for units qualified on or after January 1, 2017 and will apply to projects seeking capacity for the Managed Growth Sector in 2018. 14.05(l)4, 5.

chart

 

Any excess of the SREC factor accumulated during the 40 quarters will be retired by NEPOOL-GIS. After 40 quarters of SREC-II eligibility, the system will cease to produce SREC-IIs and will begin producing Class-I credits for 100% of the MWh that the system generates. 14.05(9)(k).

Any solar photovoltaic facility larger than six MW in capacity installed on the same parcel of land and meeting all other requirements under SREC-II may qualify only for RPS Class I Renewable Generation Attributes. 14.05(9)(a). The SREC-II program capacity cap is the aggregate eligible capacity, in MW, of Solar-Carve Out II Renewable Generation Units qualified by the Department equal to 1600 MW minus the Solar Carve-Out Program Capacity Cap. 14.02.

B. Eligibility for SREC-II in the Managed Growth Sector

SREC-II facilities in the Managed Growth Sector will be eligible for qualification subject to several provisions, including annual capacity blocks, which will be announced no later than June 30 of each subsequent Compliance Year for the Compliance Year two years in the future.

  • For Compliance Year 2014, the annual capacity block shall be 26 MW;
  • For Compliance Year 2015, the annual capacity block shall be 80 MW. 14.05(m).

C. Procedure for Applying for an Assurance of Qualification & Financing Opportunities

The DOER will issue a full guideline outlining the process for providing Assurance of Qualification, though the draft revisions did not specify where or when these guidelines will be available. However, the revisions do specify that the content of these guidelines will be subject to stakeholder review and comment.

Section 14.05(o) details that the DOER shall grant an Assurance of Qualification for SREC-II facilities that have either:

  1. been granted the approval to interconnect to the grid by their local distribution company; or
  2. have provided evidence of the following:
    (a)  an executed Interconnection Service Agreement (ISA) with the distribution company; and
    (b)  adequate site control, interest, or other contractual right to construct the system at the location specified in the ISC; and
    (c)  all required governmental permits and approvals to construct the system, including building permits and notwithstanding any pending legal challenge(s) to such permits.

Section14.05(p) confirms that the DOER will establish a program utilizing ACP funds to enhance the availability of ownership financing options for SREC-II facilities. This program will be available for residential and other buildings that are owned by 501(c)(3) organizations who are incorporated under state law as not-for-profit corporations.

D. Solar Credit Clearinghouse Auction-II (SCCA-II)

Below is an overview of the Solar Credit Clearinghouse Auction under the SREC-II program. For the most part, the rules and process are similar to how the auction is run under SREC-I.

The Solar Credit Clearinghouse Auction-II for SREC-II shall be held as follows, pursuant to the draft regulations Section 14.05(9)(f)-(j):

  1. The first auction will be held each year on or before July 31.
    SCCA-II will be available for deposits between May 16 and June 15, inclusive of these dates. A 5% fee will be assessed for all SCCA-II clearinghouse prices, pursuant to the fixed price schedule available below. All SREC-II attributes deposited into SCCA-II will be eligible for two additional years.

    chart acp

    If the first auction clears, then the total amount of re-minted auction-II account generation attributes (SRECs) will be distributed to the bidders in a pro-rated manner based on their bid volume.

  2. If the first auction does not clear, then the DOER will void the auction and conduct a second auction within three business days of the first auction. The SRECs deposited into this auction will be issued eligibility for three subsequent compliance years from the year in which they were generated.
  3. If the second auction does not clear, then the DOER will void the auction and recalculate the Massachusetts Solar Carve-Out II Minimum Standard to adjust the demand before conducting a third auction, which will be held within three business days of the second auction. If this third auction does not clear, then the demand will be reallocated on a pro rata basis, and the excess will be returned to sellers with the previously-issued three year eligibility. These SRECs will be ineligible for future auctions.

E. Renewable Energy Portfolio Standard & Compliance Obligation Formula

The compliance obligation formulas remains the same as under 14.07(2)(d): For each subsequent Compliance Year (CY), the total compliance obligation shall be equal to the total compliance obligation from the previous Compliance Year (CY-1), plus the difference between the Solar Carve-Out Renewable Generation Attributes projected to be generated for the previous Compliance Year and the Solar Carve-Out Renewable Generation Attributes actually generated for the Compliance Year two years  prior (CY-2) which is multiplied by 1.3, plus the number of Solar Carve-Out Renewable  Generation Attributes from the Compliance Year two years prior banked as provided under 225 CMR 14.08(2), plus the number of Solar Carve-Out Renewable Generation Attributes from the Compliance Year two years prior deposited into the Solar Credit Clearinghouse Auction Account.

Total Compliance ObligationCY = Total Compliance ObligationCY-1 + [Total SRECs Generated (projected)CY-1 – SRECs Generated (actual)CY-2] x 1.3 + Banked VolumeCY-2 + Auction VolumeCY-2

The SREC-II Minimum Standard will not apply to the portion of load-serving entities’ (LSEs) energy sales that were subject to electricity contracts signed prior to the implementation of the program, provided that the LSE in the party to the contract provides the DOER with evidence of such contract. 14.07(3)(b).

Section 14.07(3) establishes the SREC-II Minimum Standard, which will be calculated and announced by the DOER not later than August 30 of the preceding Compliance Year as specified in the Section. 2014 and 2015 demand has already been established:

  • For Compliance Year 2014, the total compliance obligation is 41,279 MWh of SREC-II generation by 85 MW of SREC-II capacity across the sectors. 14.07(3)(c).
  • The total compliance obligation for Compliance Year 2015 is 161,958 MWh, generated by 230 MW of SREC-II capacity across the sectors. 14.07(3)(d).

For each subsequent Compliance Year (CY), the total compliance obligation shall be determined by the DOER as equal to the sum of the following quantities of generated and projected SREC-IIs:

  1. Installed SREC-II Supply (installed facilities);
  2. Qualified but not Installed SREC-II Supply (facilities that have been initiated but are not yet online);
  3. Projected New Supply (based on prior growth trends by market sectors and annual capacity blocks, such that cumulative installed capacity does not exceed the cumulative installed capacity target for the end of the year as follows);max capcity table
  4. Rollover Volume (those SREC-IIs that remain eligible for compliance from re-minted SCCA-II generation and banked SREC-IIs); and
  5. Third Round Auction Volume Doubling (in the case of a third round SCCA-II).

Section 14.07(3)(g) assures that the DOER will provide a clear and precise methodology by which it will calculate the quantities set forth above and the Compliance Obligation.

After 2020, the RPS Class I Minimum Standard shall increase by 1% per Compliance Year unless modified by law. 14.07(4).

As the rulemaking process continues, we will provide updates and additional analysis on this blog.