The Pennsylvania Solar Renewable Energy Credit (SREC) market has been through some changes since the fall of 2017. In October 2017, Governor Wolf signed Act 40 into law. On May 3, 2018, the PA Public Utilities Commission entered its final implementation order. The order clarified two main items:

1. PA certified SRECs issued for October 2017 generation and prior would maintain their PA SREC certification regardless if the generator was sited in the state or out of the state
   • Out of state generators with RECs generated from November 2017 onward were reclassified as PA Tier I eligible. The PA program administrator and PJM GATS made these updates in the tracking registry in early May 2018.
2. Some out of state generators would be eligible to temporarily maintain SREC eligibility if their SRECs were sold under a preexisting contract, executed before Act 40 became law. For the generator to maintain eligibility the contract would have to be signed directly with an Electric Distribution Company (EDC) or Electric Generation Supplier (EGS). The contracting EDC or EGS would need to file a petition for approval with PUC within 60 days of the May 3, 2018 final implementation order. If approved, the out of state generator would only be able to maintain PA SREC eligibility for the term and quantity of the contract.
   • On May 17, 2018, the PA PUC issued a follow on order that they will be taking into consideration comments filed by Community Energy to reconsider the requirements of who generators are contracted with in order to maintain PA SREC eligibility for out of state solar projects. Additionally, the PA PUC noted that it would stay the 60 day period for EDCs and EGSs to petition to qualify their contracts with out of state generators, pending further review and consideration of the comments filed by Community Energy. All PA PUC documents and comments can be found by searching Docket #2017-2631527 on the PA PUC site.

One of the most meaningful components of these changes in the PA SREC market has been the change in the price of PA SRECs. The spot market has increased more than 2.5x since this time last year (i.e. from ~$5/SREC in May 2017 to ~$13/SREC in May 2018). Pricing on a forward basis has also been positively impacted with more participants starting to show interest in transacting out the curve.

Fundamentally, the PA SREC market remains oversupplied. A very large bank of eligible SRECs from RY2016, 2017, and 2018 from sited and out of state projects (generation from October 2017 and prior) is the main driver of oversupply. Additionally, Pennsylvania’s solar carve-out is relatively small (0.50% by reporting year 2021) as compared to Maryland’s current 1.5% requirement in calendar year 2018 and New Jersey’s 3.2% requirement in reporting year 2018. For more specific details on potential supply scenarios click here for our latest PA SREC Market Update presentation.

Expected oversupply for reporting year 2018 is by nearly 2 million SRECs. While the analysis shows the oversupply becoming less meaningful moving forward, assuming relatively modest in-state build rates, the market could still expect varying degrees of oversupply (i.e. ~40-70% even in reporting year 2023). One potential factor that could change this oversupply dynamic dramatically would be market participants willingness to purchase PA certified out of state SRECs from the existing SREC bank (i.e. generation from October 2017 and prior). Since the PA PUC final implementation order has been clarified and PJM GATS and the PA AEPS administrator adjusted the SRECs in the tracking registry, demand for in-state SRECs has been much more prevalent than for out of state certified SRECs. The presentation enclosed herein includes a scenario demonstrating what supply would look like relative to demand if none of the out of state certified bank from October 2017 generation and prior were used in meeting current and future RPS obligations. It does not appear likely that this preference for in-state only demand would remain prevalent for a long period of time. It has been presented simply to show a scenario that would lead to one scenario of under-supply that would likely be recognized by the market and quickly corrected.

Lastly, due to the PA PUC staying the petition to qualify of out of state PA forward contracts for continued eligibility during the contract term, it is still unknown how these contracts will impact future supply. The enclosed analysis notes that this has not been taken into consideration in the scenarios presented herein, but please keep this in mind as you are reviewing this information.

As more updates become available we’ll provide more information. Should you have any questions about the enclosed analysis or need REC transaction and management services, please contact us.