MA16 SREC-I Market Review

Posted November 3rd, 2016 by SRECTrade.

With the October issuance of Q2 2016 SRECs behind us, we are now approximately halfway through the 2016 energy year in Massachusetts. This blog post will take into account observed issuance numbers from the first half of the year and use projections for future issuance periods to understand what caused the fall in MA16 SREC-I prices from $450+ in January to more recent bids of $380. We will look at the supply and demand balance in order to survey what may be coming in the months ahead.

Recall that demand is driven by retail electric sales in the State. The latest data we have comes from 2014, a year in which 48,129,294 MWh were sold. If we assume that retail electricity sales are flat and we apply the obligation of 1.76% and then adjust for exempted load, we derive a total estimated demand of 833,780 SRECs:

MA16 SREC-I Demand

On the supply side of the market, the simplest analysis assumes the market generates nearly 784,000 SRECs and when combined with the re-minted volumes from this year’s SCCA (1,898), then we get a total supply of 785,886. When compared to the demand outlined above, we conclude the market is short nearly 48,000 SRECs.

MA16 REC-I simple supply

What would explain falling prices in a market that is potentially under-supplied? The quick answer is that perhaps retail sales of electricity are falling instead of flat, which would lower the demand. Alternatively, perhaps the supply of SRECs is higher than detailed. We’ll examine some supply scenarios first.

One component of supply is the banked SRECs from prior years. Retail suppliers can bank up to 10% of their annual obligation for use in future years. The maximum volume of banked RECs in the market is estimated at 65,382 – the sum of the total obligation in 2014 and 2015 multiplied by 10%. If all of those SRECs were brought to market in 2016, then we would see the market long by 17,488 SRECs. We see that scenario as unlikely since 2015 was short and the bank may have been used to avoid paying Alternative Compliance Payments (ACPs). On the other hand, it’s possible that between re-minted SRECs from the 2013 and 2014 SCCCA and banked volumes, that upwards of 15,000 SRECs from prior vintages may impact the 2016 market. This source of supply would help to tighten the balance of supply and demand, but not necessarily push to over-supply.

Examining a different scenario on the demand side, even if retail sales were down 3%, the total SREC demand would still sit at 808,414, leaving a tight, yet still under-supplied market based on the simpler supply analysis.

Another element worth mentioning is liquidity. While a healthy market needs liquidity from both buyers and sellers in order to function properly, we will direct our attention to the buy-side. Because there are far more sellers than buyers in this market, an absence of even a handful of buyers is far more impactful to the efficiency of the SREC markets than the absence of an equivalent number of sellers.

In recent months we have observed a noticeably subdued level of activity from buyers. What happens when SRECs are issued and a bunch of sellers come into a quiet market? As evidenced from pricing over the last month, bids start to retreat:

Market_Insights___SRECTrade

A simplistic read of the current state of the market is that prices have dropped due to the possibility of oversupply. However, deeper examination of current supply and demand in SREC-I markets points towards a tighter, more balanced market. The bearish sentiment reflected in recent weeks may actually reflect a lack of activity from natural compliance buyers in the face of a glut of supply coming to market after Q2 issuance. These two scenarios mean very different things for medium to long term “equilibrium” pricing in the SREC-I market. A structural and persistent oversupply, a scenario we do not perceive as likely, would mean that lower prices are justified and here to stay. A mismatch of liquidity due to trading preferences of buyers and sellers however would point towards short term volatility but longer term stability in supportive SREC prices.

As always, we will continue to provide follow-up analysis as more information becomes available.  Feel free to reach out to your contacts on SRECTrade’s brokerage desk with any questions you may have.

 

Disclaimer. This document, data, and/or any of its components (collectively, the “Materials”) are for informational purposes only. The Materials are not intended as investment, tax, legal, or financial advice, or as an offer or solicitation for the purpose or sale of any financial instrument. SRECTrade, Inc. does not warranty or guarantee the market data or other information included herein, as to its completeness, accuracy, or fitness for a particular purpose, express or implied, and such market data and information are subject to change without notice. Past performance should not be taken as an indication or guarantee of future performance, and no representation or warranty, express or implied, is made regarding future performance. Any comments or statements made herein do not necessarily reflect those of SRECTrade, Inc. SRECTrade, Inc. may have issued, and may in the future issue, other communications, data, or reports that are inconsistent with, and reach different conclusions from, the information presented herein.

Copyright. This document is protected by copyright laws and contains material proprietary to SRECTrade, Inc. This document, data, and/or any of its components (collectively, the “Materials”) may not be reproduced, republished, distributed, transmitted, displayed, broadcasted or otherwise disseminated or exploited in any manner without the express prior written permission of SRECTrade, Inc. The receipt or possession of the Materials 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 the Materials is granted, reference and sourcing must be attributed to the Materials and to SRECTrade, Inc. If you have questions about the use or reproduction of the Materials, please contact SRECTrade, Inc.

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.

New Jersey SREC Update – October 2016

Posted October 11th, 2016 by SRECTrade.

New Jersey has continued to be the most active SREC market both in terms of volume and price action, with the market experiencing a small sell-off in recent days.  We maintain that this activity is not necessarily indicative of the true fundamental balance of the market, but rather due to selling pressure from a small group of market participants.  In order to provide a more objective perspective on the state of the New Jersey solar market we have updated our capacity presentation, available here.

As of August 31, 2016 there were 1,871.9MW of solar capacity online and generating SRECs in the state of New Jersey.  This was up 20.5MW from the New Jersey BPU solar installation report for July 2016, and up 78MW from our last NJ update after the solar installation report for June 2016.

After the June report, we emphasized that the headline number reported in the BPU’s solar installation reports can be slightly misleading if taken solely at face value.  A deeper dive into what exactly contributed to the increase from the last report provides additional insight into the true state of the New Jersey market.  The 20.5MW increase from the July 2016 report combines the following:

  • 1.5MW increase for upward revisions in 2011-2014 monthly figures
  • 1.6MW increase for upward revisions in 2015 monthly figures
  • 11.3MW increase for upward revisions in 2016 monthly figure for January-June
  • 5.5MW increase for upward revisions in July 2016, bringing the monthly build from 7MW to 12.5MW
  • 10.9MW addition for new build in August 2016
  • 10.2MW decrease for downward revisions in “estimated installations” (essentially the BPU pipeline figure for old PTO applications that have not yet been processed)

 

This breakdown helps illustrate a few important trends.  First, the magnitude of these revisions has decreased sharply from previous reports, indicating that the BPU may have begun to catch up on the back-dated PTO applications that have served to inflate the headline month-on-month change in reported capacity since Applied Energy Group took over reporting in May of this year.  Second, the rate at which new capacity is being built and brought online has slowed markedly since the peak we witnessed in the first half of this year.  The average build rate for December 2015 through May 2016 was an impressive 33MW/month, however we believe the current last twelve month (LTM) average of 23.9MW/month is a closer representation of the sustainable long term trend.  That LTM is what we use as the base case (Case 2 below) for our resulting scenario analysis and future projections.

In the graph below you’ll find the representation of our projection analysis. Under the current RPS schedule and using the observed LTM build rate as our base case (i.e. Case 2), we see 2017 as slightly over supplied.  The market balance continues into a slight oversupply in 2018, with the degree of oversupply steadily increasing year-on-year through 2021.  All data and projections are available in our presentation hyperlinked above.

 

New Jersey SREC S&D

 

As always, we will continue to monitor the development of the market trends mentioned above and share our analysis as new information becomes available.  In the meantime please feel free to reach out to your SRECTrade coverage with any questions or comments.

 

Disclaimer. This document, data, and/or any of its components (collectively, the “Materials”) are for informational purposes only. The Materials are not intended as investment, tax, legal, or financial advice, or as an offer or solicitation for the purpose or sale of any financial instrument. SRECTrade, Inc. does not warranty or guarantee the market data or other information included herein, as to its completeness, accuracy, or fitness for a particular purpose, express or implied, and such market data and information are subject to change without notice. Past performance should not be taken as an indication or guarantee of future performance, and no representation or warranty, express or implied, is made regarding future performance. Any comments or statements made herein do not necessarily reflect those of SRECTrade, Inc. SRECTrade, Inc. may have issued, and may in the future issue, other communications, data, or reports that are inconsistent with, and reach different conclusions from, the information presented herein.

Copyright. This document is protected by copyright laws and contains material proprietary to SRECTrade, Inc. This document, data, and/or any of its components (collectively, the “Materials”) may not be reproduced, republished, distributed, transmitted, displayed, broadcasted or otherwise disseminated or exploited in any manner without the express prior written permission of SRECTrade, Inc. The receipt or possession of the Materials 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 the Materials is granted, reference and sourcing must be attributed to the Materials and to SRECTrade, Inc. If you have questions about the use or reproduction of the Materials, please contact SRECTrade, Inc.

PJM GATS Solar – Registered Capacity Update as of September 2016

Posted September 29th, 2016 by SRECTrade.

The following post is a monthly update outlining the megawatts of solar capacity certified to create SRECs in the PJM GATS solar REC markets that SRECTrade serves. All data is based on the information available in PJM GATS as of the date noted.

PJM CapacityHelv

The chart above compares the megawatts (MWs) registered in PJM GATS as of September 23, 2016 (the blue bar) to the estimated RPS solar MWs needed to be operational, through the duration of the current reporting year, to meet each market’s RPS targets (the green bar). Note that the Estimated RPS MWs quantity does not take into consideration SRECs eligible from previous reporting years and is only used as an estimate relative to the current MWs registered in PJM GATS. All actual RPS requirements are represented in megawatt hours (i.e. SRECs) required per year. The installed capacity operational over that time will produce SRECs, in addition to any eligible SRECs from previous periods, to end up with the final supply relative to that reporting year’s demand. For estimates on required number of SRECs per reporting year across the SREC markets SRECTrade covers, please visit our state market summary pages.

As of August 31st, New Jersey had installed a cumulative total of 1,871.9MW of nameplate capacity, 139.7MW of which had been installed since the Applied Energy Group’s May 31st report (June-August).  Their Solar Installation Report and Solar Pipeline Report can be found online here on the New Jersey Office of Clean Energy website, and our most recent analysis of those numbers can be found here. Please note that this analysis includes 15.6MW of estimated installations (final “as-built” applications submitted, but not yet processed).

Additionally, please note the following in the figures presented above:

OH2016: Represents all OH eligible solar facilities and includes some facilities that are cross-registered in PA. If any systems were eligible in higher priced markets, such as DC, the capacity was excluded from OH eligibility as it could be sold at a higher price in DC.

DE2016: Represents all solar facilities eligible for the DE solar RPS requirement. Some facilities registered in DE are also eligible in PA and could impact that market’s supply.

DC2016: Includes all systems eligible for the DC SREC market. If a system was eligible in another market, it was not included there given the current pricing for DC SRECs.

PA2017: Represents all solar facilities eligible for the PA SREC market. Some systems are cross-registered in OH as well. If a system was eligible in any higher priced markets (i.e. NJ or MD sited systems that cross-registered in PA) they were not included in the total MW balance displayed above.

MD2016: Includes all MD eligible solar capacity registered in PJM GATS as of the date noted. If projects were cross-registered in Washington D.C., the capacity was not allocated to Maryland’s eligible MW total.

NJ2017: The balance noted above represents the 8/31/16 Solar Installation Report reported by Applied Energy Group.

PJM GATS Registered Solar Projects Summary

There are 101,215 facilities across 3,430MW registered in PJM GATS as of 9/23/2016.

432 projects are 1MW or larger in capacity, representing 1763.9MW or 51.4% of the qualified capacity. There are 101 projects that are 5MW or larger. These make up 32.7% of all qualified capacity, 1,122.1MW total, in PJM GATS.

Note: SREC requirements for markets without fixed SREC targets have been forecast based on the EIA Report “Retail Sales of Electricity by State by Provider”. Projected SRECs required utilizes the most recent EIA electricity data applying an average 1.0% 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 1,200MWh, in PJM GATS states, generated per MW of installed capacity per year.

Massachusetts SREC-II Update – September 2016

Posted September 26th, 2016 by SRECTrade.

The Department of Energy Resources (DOER) published an updated list of projects with a Statement of Qualification (SQA) on August 25, 2016. Since the last update in July not much has changed in the SREC-II landscape. Expected oversupply still remains the reality reflected in pricing for 2016. Similarly, monthly build-rates are more or less unchanged. The total installed capacity increased 65MW since the last update, bringing us to 573.54 MW. You can find our in-depth analysis here. Below, please find some highlights.

Based on the latest data, there are currently 573.54 MW of operational assets, with an additional 956.87 MW that is qualified, but not operational:

Installed Capacity

Finally, based on current build rates, we continue to see a gross oversupply for the MA2016 SREC-II market:

S, D

Thus far, the market has generated 82,758 MA2016 SREC-IIs and based on current build-rates and installed capacity, we estimate an additional 473,084 SRECs coming later in the year. Adding in the re-minted volumes of 67,046, we see a potential pool of supply upwards of 622,888. Compare that supply figure to the demand side of approximately 327,471 and we conclude the market is oversupplied by 90%. In other words, nearly half of all MA2016 SRECs may find their way to the Solar Credit Clearinghouse Auction next year.

 

Disclaimer. This document, data, and/or any of its components (collectively, the “Materials”) are for informational purposes only. The Materials are not intended as investment, tax, legal, or financial advice, or as an offer or solicitation for the purpose or sale of any financial instrument. SRECTrade, Inc. does not warranty or guarantee the market data or other information included herein, as to its completeness, accuracy, or fitness for a particular purpose, express or implied, and such market data and information are subject to change without notice. Past performance should not be taken as an indication or guarantee of future performance, and no representation or warranty, express or implied, is made regarding future performance. Any comments or statements made herein do not necessarily reflect those of SRECTrade, Inc. SRECTrade, Inc. may have issued, and may in the future issue, other communications, data, or reports that are inconsistent with, and reach different conclusions from, the information presented herein.

Copyright. This document is protected by copyright laws and contains material proprietary to SRECTrade, Inc. This document, data, and/or any of its components (collectively, the “Materials”) may not be reproduced, republished, distributed, transmitted, displayed, broadcasted or otherwise disseminated or exploited in any manner without the express prior written permission of SRECTrade, Inc. The receipt or possession of the Materials 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 the Materials is granted, reference and sourcing must be attributed to the Materials and to SRECTrade, Inc. If you have questions about the use or reproduction of the Materials, please contact SRECTrade, Inc.

Maryland SREC Update – September 2016

Posted September 15th, 2016 by SRECTrade.

As the growth of the Maryland solar market continues to outpace the state’s RPS framework, the Maryland SREC market has become more and more challenging to navigate.  The SREC market is clearly oversupplied and the market is trading in line with expectations that this will continue well into the future.  In order to better inform the conversation around the true state of the MD SREC market we’ve taken a closer look at data made available by the PJM GATS regarding the rate at which new solar capacity is being brought online in the state.

You can find a copy of our updated Maryland capacity presentation here.

Through August 2016 there were 157,377 SRECs left over from compliance years 2014 and 2015.  Thus far in 2016 (through July 2016 generation), 344,792 CY2016 SRECs have also been issued.  Assuming that the observed average monthly build rate of 21.4 MW/month continues through the year, we project that 293,183 additional SRECs will be generated in compliance year 2016.  Taking together the existing inventory of available prior-period SRECs together with the projected production for the remainder of 2016, we foresee an oversupply of 363,600 SRECs, or approximately 84% over the total 2016 RPS requirement, by the end of the year.

untitled

There are a few important trends to note here.  First, while the trailing twelve month (TTM) average monthly build has technically increased since our last Maryland capacity update in June (21.4MW/month now vs. the 19.6MW/month reported in June) this is actually due to the lower build rates of Q2 2015 falling out of the TTM measurement.  The most recent data shows that the build rate actually peaked in the three months of December 2015 through February of 2016.  Those three months averaged a 35.9MW/month build rate, while the three months immediately following dropped to a significantly less aggressive 17.5MW/month average.  This shows that the rapid growth witnessed in the Maryland market has indeed begun to slow due to weaker support from the SREC market.

Secondly, this recent slow down also has significant implications for the likely path the Maryland market will follow over the coming years.  As we have already seen monthly build numbers retreat from their Dec15-Feb16 highs, we are more confident that the Maryland market will fall into a long term trend somewhere between 50% and 75% of the current TTM average of 21.4MW/month. The enclosed analysis includes two scenarios, the first with the RPS requirements as currently set and the second with the RPS increase as proposed under SB0921/HB1106 The RPS increase proposed was vetoed by Governor Hogan in May of 2016. While industry stakeholders continue to advocate for an RPS increase, it is uncertain what form a new piece of legislation could take. For purposes of showing the state of the market under current and the vetoed legislation (i.e. some form of increase), supply and demand scenarios have been presented under both RPS requirements. Assuming a build rate decline of 50-75% of current TTM average, the market will be in a persistent state of oversupply within the range of approximately 50% to 115% through 2018 under both RPS requirements.

We want to emphasize that these projections are derived entirely from available historical data based on observations of assets built and registered with PJM GATS.  The monthly build rates remain subject to change for some time into the future as the registry receives and processes new project registrations.  Also, these numbers do not incorporate data from the PJM interconnection queue.  While this queue is noteworthy due to the presence of multiple relatively large utility-scale installations, it is impossible to predict which of these will indeed come online and which will fall away because of deteriorating project economics.  We acknowledge that if even one of the largest five projects listed in the interconnection queue comes online with SREC eligibility our projections would need to be significantly revised.

We will continue to track the state of the Maryland SREC market as more data is made available.  Please feel free to reach out to anyone on the SRECTrade brokerage team to discuss this analysis or any of the assumptions used herein.

 

Disclaimer. This document, data, and/or any of its components (collectively, the “Materials”) are for informational purposes only. The Materials are not intended as investment, tax, legal, or financial advice, or as an offer or solicitation for the purpose or sale of any financial instrument. SRECTrade, Inc. does not warranty or guarantee the market data or other information included herein, as to its completeness, accuracy, or fitness for a particular purpose, express or implied, and such market data and information are subject to change without notice. Past performance should not be taken as an indication or guarantee of future performance, and no representation or warranty, express or implied, is made regarding future performance. Any comments or statements made herein do not necessarily reflect those of SRECTrade, Inc. SRECTrade, Inc. may have issued, and may in the future issue, other communications, data, or reports that are inconsistent with, and reach different conclusions from, the information presented herein.

Copyright. This document is protected by copyright laws and contains material proprietary to SRECTrade, Inc. This document, data, and/or any of its components (collectively, the “Materials”) may not be reproduced, republished, distributed, transmitted, displayed, broadcasted or otherwise disseminated or exploited in any manner without the express prior written permission of SRECTrade, Inc. The receipt or possession of the Materials 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 the Materials is granted, reference and sourcing must be attributed to the Materials and to SRECTrade, Inc. If you have questions about the use or reproduction of the Materials, please contact SRECTrade, Inc.

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.

D.C. RPS Bill Published in Register

Posted August 23rd, 2016 by SRECTrade.

Following Mayor Bowser’s signature last month, the Renewable Portfolio Standard Expansion Amendment Act of 2016 is now published in the D.C. Register.

A21-466 was published in Volume 63, Number 33 of the District of Columbia Register on August 5, 2016 under the Actions of the Council of the District of Columbia. The PDF of the issue is available here.

As enacted, B21-0560 raises the renewable portfolio and solar requirements to 50% and 5% by the year 2032, respectively, and adds waste heat from combined and sanitary sewage systems and effluence from wastewater treatment to the list of Tier 1 renewable sources. In addition, the bill increases financial penalties for electricity suppliers who fail to comply with the annual renewable energy portfolio standard requirements. This financial penalty is known as the Alternative Compliance Payment, or ACP. Finally, the bill establishes a program within the Department of Energy and the Environment to assist low-income homeowners with installing solar systems on their homes.

MA DOER Issues Draft Guidelines for Revised SREC-II Market Factors

Posted August 16th, 2016 by SRECTrade.

Yesterday, the Massachusetts Department of Energy Resources (DOER) announced its draft Guidelines relating to the revised SREC factors for the Solar Carve-out-II program. The draft Guidelines can be found on the DOER’s website, which includes the Adjusted SREC Factor Guideline Draft as well as draft versions of the 225 CMR 14 Solar Guideline – Extension Guideline and Detailed Construction Costs Form. The draft Guidelines follow the July 1, 2016 promulgation of the Emergency Regulations. As the DOER explains, “Recognizing that a long-term sustainable solution will take time to develop and that many projects are in advanced stages of development, the emergency regulation is intended to address market uncertainty and establish a smooth transition from SREC-II to the next incentive program.”

The draft Guidelines contain both clarification on construction timeline extensions and the revised SREC factor guidelines. For construction extensions, as provided in 225 CMR 14.05(9)(s)(4), a qualified Solar Carve-out II Renewable Generation Unit that is larger than 25 kW DC that has not received the authorization to interconnect or permission to operate by January 8, 2017, and cannot demonstrate that it is mechanically complete by January 8, 2017, can request a construction deadline extension to May 8, 2017. Extensions will be provided if a project can demonstrate to the satisfaction of the DOER that the project has expended at least 50% of its total construction costs by January 8, 2017.  The 225 CMR Solar Guideline – Extension Guideline sets forth the procedures and requirements for Solar Carve-Out II Renewable Generation Units that seek this extension. The draft Guideline also includes an Excel Spreadsheet and Attestation Form to be completed and submitted to the DOER.

The new SREC factors, as provided for by 225 CMR 14.05(9)(l)5, shall apply to any Solar Carve-out II Renewable Generation Unit that meets the following criteria:

  1. Nameplate capacity less than or equal to 25 kW and authorized to interconnect after January 8, 2017; or
  2. Nameplate capacity greater than 25 kW that receives an extension pursuant to 225 CMR 14.05(9)(s)4.a.

The Adjusted SREC Factor Guideline provides new SREC Factors for each SREC Market Sector. Under the revised Guideline, all projects that meet the criteria outlined above shall receive an SREC Factor that is reduced by approximately 15-20% from current values. A comparison of the current SREC Factors and the revised SREC Factors is provided below:

Screen Shot 2016-08-16 at 5.13.34 PM

 

Screen Shot 2016-08-16 at 5.13.42 PM

The DOER invites comments on the draft Guidelines through August 22, 2016 at 5:00PM. Comments can be sent to DOER.SREC@state.ma.us with the subject line “SREC-II Guideline Comments”.

Additional information concerning the SREC-I & SREC-II markets in Massachusetts can be found on our Massachusetts market page.

New Jersey SREC Update – August 2016

Posted August 15th, 2016 by SRECTrade.

We recently received an update on the New Jersey solar market from the office of New Jersey’s Clean Energy Program, bringing us up to date on new solar capacity built through June.  As of June 30th, New Jersey had a total installed capacity of 1,793.79MW – a 61.49MW addition from the figure previously reported as of the end of May.

The 61.49MW addition is obviously noteworthy at first glance, and the market has immediately responded by selling off significantly in the days that followed the report’s release.  A closer look into the data, however, provides a more nuanced understanding of what that figure really represents.  Given the magnitude of the market reaction after this release we took the opportunity to update our New Jersey capacity models to provide a framework to better understand the data.

You can find our updated New Jersey SREC capacity presentation here.

While it is true that 62MW of new projects were added to the cumulative total of installed capacity, that number actually represents revised figures for monthly installations dating back to January 2015.  The 62MW can be broken out as follows:

  • 11MW of upward revisions attributed to 2015 monthly figures
  • 32MW of upward revisions attributed to 2016 monthly figures
  • 19MW of new build attributed to June 2016

Given the distribution of the newly reported capacity increase, the result on the observed average build rates is not quite as extreme as we have seen other groups report.  Using the newly updated numbers, the trailing twelve month average build rate is about 22.5MW/month and the 2016 YTD average is 25.7MW/month.

In aggregate, the New Jersey RPS is quite large and this recent surge in build in and of itself does not necessarily tip the overall balance of the SREC market.  While we have seen a broad sell off in New Jersey SRECs across most vintages, we believe the New Jersey market can maintain current pricing even if the build rate remains elevated in the short term.  What has most likely sent SREC prices lower is the possible impact that a more long-term increase in build rates might have on the balance of the NJ SREC market.

Looking ahead there are two very different possible scenarios.  For the sake of keeping RPS comparisons constant through this analysis, we will make the assumption that NJ SB2276 (which increases the NJ RPS solar requirement slightly) successfully makes its way through the legislative process and is formally adopted.   First, the solar sector could react to the recent drop in SREC values and regress from its current trend to a less aggressive – though still above the historical average – rate of 17MW per month.  A build rate averaging somewhere close to 17MW per month would keep solar installations just slightly ahead of goals set by the current RPS schedule, leaving us no more than 5% oversupplied in any given year through 2021.  This would likely leave SREC prices stable and trading at consistently strong levels.

The alternative is to presume that the most recent increase represents a “new normal” for New Jersey solar.  An average build rate of 34MW per month, which more closely tracks the current trend, extrapolated out over the next five years would result in a very significant oversupply that would almost certainly push SREC prices lower in 2019 and beyond.   A build rate anywhere near 34MW per month eventually outpaces the growth built into the current RPS schedule and overwhelms the market structure that has been put in place through recent legislation.

We will focus on following how this trend develops over the coming six months.  If the solar industry does indeed respond to the price signals being sent by the NJ SREC market, and build rates normalize to more sustainable rates, then New Jersey solar economics will continue to benefit from strong SREC prices.  If, however, developers ignore these signals and continue to aggressively install new assets irrespective of RPS support we will likely see SREC prices continue to retreat in a manner that reflects the underlying shift in the balance of SREC supply and demand.

As always, we will continue to monitor these trends and share our analysis as new information becomes available.  In the meantime please feel free to reach out to your SRECTrade coverage with any questions or comments.

 

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