New Jersey SREC Update – June 2016

Posted June 17th, 2016 by SRECTrade.

On Monday evening we received a much anticipated update on the growth of New Jersey’s solar capacity.  Applied Energy Group made their analysis available via New Jersey’s Clean Energy Program website, providing new information on the monthly build rates and overall size of the New Jersey solar market.  

As in most other SREC markets, the beginning of the year has been exceptionally strong for new solar development in New Jersey.  As of May 31st, New Jersey had installed a cumulative total of 1,732.3 MW of nameplate capacity.  88 MW of that capacity was installed just in the last three months since the data was last reported on February 29th.  Also of note, a full 89 MW of the new supply added thus far in 2016 is categorized as Grid Supply, putting this year on track to be the largest year to date for non-behind-the-meter solar development.

The New Jersey SREC market was exceptionally busy on Tuesday and Wednesday as the market digested this new data.  Tuesday morning  the market was predominately offered as sellers attempted to lock in the value that has been available for spot and forward contracts.  As always, we enjoy seizing these opportunities of higher than normal market activity to offer a dose of objective market analysis to the ongoing dialogue.

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

The average rate of new solar construction has indeed increased over the last few months.  88 MW came online in March, April and May of this year, increasing the trailing twelve month average build rate to 20.5 MW/month.  Although this headline number justifiably commands attention, we believe that it is important to evaluate this increase in the context of New Jersey’s equally robust RPS requirements.  In our presentation, we put forward scenario analyses for both the currently adopted RPS percentages as well as the proposed higher RPS percentages contained in Senate Bill 2276 (our previous post on the proposed legislation can be found here).

Our analysis finds that even under the current RPS, a continuous 20.5 MW monthly build rate would not lead to significant oversupply (defined as an imbalance above 25% of the annual requirement) until midway through 2020.  Under either RPS schedule, and even with a build rate that grows to an impressive 30.8 MWs per month, the imbalance of supply and demand would not exceed 20% until 2019 at the earliest.

With that said, passage of SB2276 is critical to the longer term sustainability of the New Jersey solar market.  The proposed demand “pull forward” mechanism central to the bill helps alleviate concerns that the solar market will be able to count on supportive SREC pricing from 2020 onward.  If capacity growth is assumed to remain at a constant rate, but no adjustment is made to the current RPS schedule to match that pace, the SREC market will indeed become increasingly oversupplied from 2020 onward.

As always, please feel free to contact your SRECTrade brokerage team member for any further clarification or discussion of our data.  We will continue to follow the development of the legislative process closely and provide you with updates as they become available.

 

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 – June 2016

Posted June 10th, 2016 by SRECTrade.

Much has been made of Governor Hogan’s recent veto of the Clean Energy Jobs – Renewable Energy Portfolio Standard Revisions bill (SB0921/HB1106) and its implications for the long term health of the state SREC market.  Market weakness due to fundamental oversupply has been exacerbated by uncertainty as to the likelihood of the Maryland legislature to expand state renewables markets in step with increasing supply.  With the Maryland SREC market trading at all time lows, we feel that it is important for market participants to be able to base their opinions on accurate empirical data.  As such, we have updated our supply and demand scenario models to reflect the most recent available capacity information made available by PJM GATS.

Our updated Maryland capacity presentation can be found here.

Through May 2016 there was approximately 156,682 SRECs left over from compliance years 2014 and 2015.  Thus far in 2016, 144,133 CY2016 SRECs have also been issued.  Assuming that the observed average monthly build rate of 19.6 MW/month continues through the year, we project that 556,507 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 425,535 SRECs  by the end of 2016.

In this latest capacity analysis update we have included parallel analyses for the projected supply/demand balance in future years.  Looking out to 2022, we demonstrate how that balance would evolve under both the currently adopted RPS as well as under the recently proposed RPS.  We have also made a slight change to the range of scenarios we present.  Whereas we typically present this analysis extending the current trailing twelve month average build rate through the full term of the analysis, and two more scenarios where the build rate both increases and decreases slightly, we have chosen to adjust our methodology.  The current build rate of 19.6 MW/month is quite strong relative to historical averages, influenced primarily by above average build numbers for December 2015 through February 2016.  This increase may have been caused by the “ITC cliff” confronted at the end of 2015 or by stronger SREC prices in the summer and fall of 2015.  Whatever the cause, those factors are no longer relevant for the purposes of this analysis, and it is reasonable to believe that monthly build numbers will decrease from here.  Our case 1 and 2, therefore, are reflective of a build rate that is 50% and 75% of the trailing twelve month average.

While the market is clearly oversupplied under almost all scenarios we think it is important to note that the proposed RPS significantly decreases the percentage oversupply in later years, decreasing the oversupply by almost half in some instances.  We point this out to illustrate that the current state of the market may not be as dire as some market participants believe.  We maintain that an oversupplied market is not necessarily a broken market.  One of the advantages of a market-based mechanism is that price fluctuations provide price signals to market participants considering whether to initiate additional projects.  Ideally, the low level of SREC pricing today will lead a significant portion of the current project queue to wait on adding new capacity until the supply and demand balance normalizes.

With that said, the greatest uncertainty as to the future health of the Maryland SREC market is what portion of the PJM interconnection queue will ultimately be built.  There are several large utility scale projects with nameplate capacity of 100 MW or more that could drastically change the supply and demand balance to a point where the only solution would be legislation to either increase the state RPS or restrict eligibility to the existing market.  Our analysis does not account for this potential outcome but we acknowledge that it is certainly a plausible scenario.

We will continue to monitor the state of the Maryland SREC market as more data is made available regarding trends in monthly build rates and new projects that are awarded SREC eligibility.  We will also continue to publish information regarding the Maryland legislative process and the status of the solar carve out.  Please reach out to the SRECTrade team with any questions or feedback.

 

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.

D.C. RPS Bill Passes in First Reading before the Council

Posted June 7th, 2016 by SRECTrade.

Today, the D.C. Council held its first hearing on B21-0650, the Renewable Portfolio Standard Expansion Amendment Act of 2016. The bill, which was introduced earlier this year, passed unanimously in the first hearing, but must still pass a second hearing in July, and a Council vote as early as mid-July, before it passes to the Mayor for signature.

The RPS Expansion Amendment Act of 2016 will increase the RPS and solar carve-out requirements to 50 percent and 5 percent by the year 2032, respectively, and increase alternative compliance payments (financial penalties) for electricity suppliers who fail to comply with RPS requirements.

You can read our prior post on the RPS bill here, and subscribe to our blog to stay up to date on the bill’s progress with the Council and Mayor.

New Jersey RPS Bill Proposes Pull Forward to Address Oversupply

Posted June 3rd, 2016 by SRECTrade.

Last week, New Jersey Senators Robert Smith (D) and Christopher Bateman (R) introduced a bipartisan energy bill in the Senate, with a broad coalition of support from solar energy owners, installation and development stakeholders, renewable energy advocates, and other environmental groups. S2276, which was referred to the Senate Environment and Energy Committee upon its introduction on May 23, will adjust New Jersey’s renewable portfolio standard (RPS) to address the impending “solar cliff” of oversupply. In addition, the bill establishes a Solar Energy Study Commission to enable the Garden State to evaluate potential paths and long term solutions for the future of solar policy in the New Jersey.

Under the Solar Act of 2012, New Jersey utilized a “pull forward” mechanism to adjust the RPS so that the increased demand could absorb an excess of SRECs in the market; unfortunately, the mechanism created a “valley of death” starting in Energy Year 2019 (June 2018), with initial impact hitting in EY2017 and EY2018. Based on current build rates, the market may build between 80 MW and 231 MW more than the RPS will require in those years. In the EY2019 to EY2025 years, the market may build between 183 MW and 335 MW in excess of the RPS demand. Under current conditions, it is not until EY2026 that retirement impacts will provide relief to the oversupply.

Figure 1 below shows SRECTrade’s projections for three potential capacity growth scenarios, and the resulting oversupply/undersupply, based on the current RPS schedule. Case 2 is the base case, where 15.6 MW per month is the historic trailing twelve month (TTM) average build rate in New Jersey. Case 1 represents the bear case, or 75%, of the TTM average build rate. Case 3 represents the bull case, or 150%, of the TTM average build rate.

SRECTrade-143x59

Scenario Chart Before Demand Pull

Percent Scenarios Before Demand Pull

Figure 1.

In an effort to forestall the cliff, S2276 proposes to once again pull forward demand from future years for the EY2019 – EY2021 energy years as follows: in EY2018, pull forward 52 MWs; in EY2019, 122 MWs; in EY2020, 115 MWs; and in EY2021, 115 MWs. This pull forward would accelerate SREC demand by 62,400 SRECs in EY2018; by 146,400 SRECs in EY 2019; and by 138,000 SRECs in each EY2020 and EY2021.  The adjustments will allow for the continued growth of New Jersey’s solar industry, which employs more than 7,100 people across 528 solar companies. To date, New Jersey has installed more than 1.6 GW of solar capacity, which is enough to power 257,000 homes and rank the State 4th in the nation.

Figure 2 below represents the potential oversupply/undersupply scenarios with the demand pull forward, using the same three potential capacity growth scenarios from Figure 1. The RPS demand figures for 2018, 2019, and 2020 have been adjusted upward by the SREC-equivalent demand increases proposed in S2276.

SRECTrade-143x59

Scenario Chart After Demand Pull

Percent Scenarios After Demand Pull

Figure 2.

In addition to the short-term solution of the pull forward of RPS demand, the bill aims to stimulate the development of long-term solutions through its establishment of the Solar Energy Study Commission. The Commission will be composed of 22 relevant stakeholders, who will provide policymakers with information and best practices for designing and implementing long term solar policies. Under the proposed amended RPS schedule, which ends in June 2021, the Commission would be charged with presenting policymakers with  recommendations for New Jersey before the end of the 2021 Energy Year.

S2276 has earned support from members of the New Jersey-based New Jersey Solar Energy Coalition, the New Jersey Solar Grid Supply Association, national and regional members of SEIA and MSEIA, and the IBEW. The bill will be heard at the Senate Environment and Energy Meeting on Monday, June 6.

SRECTrade will continue to track and report on the status of the bill as it progresses this summer.

 

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.

D.C. Council Committee Holds Public Hearing on RPS Expansion Bill

Posted May 31st, 2016 by SRECTrade.

On May 23rd, Councilmember Cheh held a public hearing on three important energy and climate change bills currently under review by the Council: B21-0650, the Renewable Portfolio Standard Expansion Amendment Act of 2016; B21-0412, the Solar Energy Amendment Act of 2015; and B21-0369, the Commission on Climate Change and Resiliency Establishment Act. The Renewable Portfolio Standard Expansion Amendment Act of 2016, which was introduced to the Council in March, will increase the RPS and solar carve-out requirements to 50 percent and 5 percent by the year 2032, respectively, and increase alternative compliance payments (financial penalties) for electricity suppliers who fail to comply with RPS requirements. Additional goals of B21-0650, in conjunction with the goals of B21-0412 and B21-0369, aim to facilitate the continued growth of solar and other renewables in the District. Currently, the bills are under review by the Council’s Committee on Transportation and the Environment, which will consider the public comments and written testimony submitted in response to the Public Hearing.

With the public comment period closed, the Committee will move to hold a mark-up meeting as soon as June 1st to consider possible amendments to B21-0650. Following this meeting, the bill should be presented for a hearing on or around June 7th, with a second hearing in July, and a vote as early as mid-July.

For more information on the District of Columbia SREC market, please visit our D.C. market page.

SRECTrade will continue to provide updates on the status of the D.C. RPS bill as it progresses with the Council.

Maryland Governor Vetoes RPS Legislation

Posted May 27th, 2016 by SRECTrade.

Earlier this afternoon, Maryland Governor Hogan vetoed the Clean Energy Jobs – Renewable Energy Portfolio Standard Revisions bill (SB0921/HB1106). Gov. Hogan’s letter to the Speaker of the House regarding the veto can be read here, wherein the Governor sites “tax increases” as his sole reason for vetoing the RPS legislation, which would have increased the State’s Renewable Portfolio Standard to 25 percent by 2020 – up from the current obligation of 20 percent by 2022 – and allowed for the continued growth of solar and other renewables in the State.

Maryland Carve-Out - 2


Maryland SACP

The RPS bill passed in the House and the Senate earlier this year with veto-proof majorities, so there is potential for the bill to become law despite the Governor’s veto. In response to the veto, proponents of the RPS bill will look to meet with House and Senate leaders to discuss a strategy for moving forward with the bill.  Unfortunately, the veto override vote will not take place until January 2017 unless a special session is held before then. However, since a special session would require the Governor’s approval, it is unlikely that a special session will be held.

SRECTrade will continue to provide updates on the status of the Maryland RPS as we acquire new information. For more information about the Maryland SREC market, please visit our Maryland Market page here.

PJM Solar – Registered Capacity Update as of May 26, 2016

Posted May 26th, 2016 by SRECTrade.

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

2016_05_26_Chart

The chart above represents the megawatts registered in PJM GATS as of May 26, 2016 (the blue bar) vs. the estimated RPS solar MWs needed to be operational all year long, in the current reporting year, to meet each market’s RPS targets (the green bar). Note, the Estimated RPS MWs 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 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.

Responsibilities for tracking NJ registered capacity have transitioned to Applied Energy Group, who has projected that its first report will be available in June.  For more information see this letter.  The NJ PJM GATS Registered MW shown in the figure above is outdated and reflects the installed solar capacity as of 2/29/2016 as reported by the NJ Board of Public Utilities and Office of Clean Energy on March 24, 2016. For the full report click here.

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.

DE2015: 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.

PA2016: 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 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.

NJ2016: The balance noted above represents the 2/29/16 MWs installed reported by the NJ BPU on 3/24/2016.

PJM GATS Registered Solar Projects Summary

There are 88,415 facilities across 3,123.8 MW registered in GATS as of 5/26/2016.

399 projects are 1 MW or larger in capacity, representing 1,590.1 MW or 50.9% of the qualified capacity. There are 86 projects that are 5 MW or larger. These make up 31.5% of all qualified capacity, 983.7 MW total, in PJM.

Note: SREC requirements for markets without fixed SREC targets have been forecast based on 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 1,200 MWh, in PJM states, generated per MW of installed capacity per year.

MA Department of Public Utilities Clarifies Net Metering Regulation

Posted May 25th, 2016 by SRECTrade.

Please note this blog post has been revised from the original May 24, 2016 post.

On Wednesday, May 18th, the Massachusetts Department of Energy Resources (DOER) notified the Department of Public Utilities (DPU) of its intent to file its determination that the 1,600 Megawatt (MW) threshold will be met on or about June 1, 2016 and requested that the DPU clarify whether facilities with private cap allocations on or before the “Notification Date” will receive the current net metering credits or the new Market Net Metering Credits. Under the recently enacted Chapter 75 of the Acts of 2016, this determination sets into motion DPU’s charge to establish a “Notification Date”, which will serve as a deadline for systems that are under the private net metering cap to be interconnected or allocated under the cap in order to receive the current net metering credits. Furthermore, the DOER requested that the DPU clarify its Emergency Net Metering Regulations and assure those facilities in receipt of net metering cap allocations on or before the Notification Date that their projects will receive net metering credits at current rates and will not receive Market Net Metering Credits (which are effectively equal to 60 percent of the retail rate). Prior to the DOER’s request, the uncertainty around the Notification Date deadline left private-cap projects in advanced stages of construction at risk of receiving Market Net Metering Credits if they failed to be interconnected by the Notification Date, creating project financing concerns.

In its May 19th Order Clarifying Emergency Net Metering Regulations, the DPU formally recognized that systems obtaining a private net metering cap allocation are “on the path toward interconnection”, since these allocations are assurances that a system will receive net metering services upon authorization to interconnect. In clarifying its policy on net metering credit eligibility, the DPU extended retail rate credit eligibility for projects that receive a private cap allocation by the Notification Date, even if those projects are not yet interconnected. Resultantly, for the duration of the Emergency Net Metering Regulations, Solar Net Metering Facilities that are interconnected or in receipt of a private cap allocation from the System of Assurance by the Notification Date shall receive retail rate net metering credits (that is, Net Metering Credits as defined in 220 C.M.R. § 18.04(1) and (5)).

This interpretation of eligibility will remain in effect only for the effective period of the Emergency Net Metering Regulations, and it is highly probable that the Notification Deadline will be set by the DPU for a date later than June 1, 2016. Following notice by the DOER that the 1,600 MW cap has been allocated, the DPU will solicit comments on the Emergency Net Metering Regulations and related issues, conduct a public hearing, and enact Final Net Metering Regulations effective July 29, 2016. Accordingly, it is possible that the Notification Deadline will be set as July 29, 2016 or possibly later than this date.

In accordance with the Order, facilities under the private net metering cap that fail to meet the Notification Date deadline will receive Market Net Metering Credits. Residential projects 10 kW and smaller on single-phase circuits, or systems under 25 kW on 3-phase circuits, will be exempt from the new rate structure under Sections 7 and 8 of the Act and are guaranteed retail remuneration rates. To be clear, facilities under the public net metering cap will continue to receive net metering credits at the current rates and will not be impacted by this Notification Deadline. For more information on current net metering and other solar legislation in Massachusetts, please visit our previous blog post on the topic here.

Massachusetts Raises Caps; Passes Net Energy Metering Bill

Posted April 17th, 2016 by SRECTrade.

On April 11, Governor Baker signed into law Chapter 75 of the Acts of 2016. The law, which was passed with an emergency preamble to have immediate effect, raises the net metering cap by 3% for private and public solar projects and will reduce the current retail remuneration rate to the wholesale rate for commercial and community solar projects once the state hits its 1600 MW solar target. Residential projects 10 kW and smaller on single-phase circuits, or systems under 25 kW on 3-phase circuits, will be exempt from the new rates under Sections 7 and 8 of the Act. Finally, the Act will permit utilities to charge solar project owners a minimum bill to cover their fixed costs.

The immediate effect of the Act will enable the stalled solar industry in Massachusetts to restart in the short term, but the Act is far from a comprehensive solution to establishing long-term, sustainable policies for solar in the Commonwealth. With the new cap estimated to be reached in some territories within a few weeks, the pressure remains on the Legislature to continue discussions on the future of solar in the state.

The Act is the result of compromise between and among the Senate, the House of Representatives, and Governor Baker. Following an impasse of the chambers’ and Governor’s respective bills last summer and into the fall, the Legislature was able to reconcile H.4173 and S.1979, passing the bill in each chamber with nearly unanimous approval. The lone “Nay” was asserted by Rep. Jonathan Hecht (D), who voiced his worry that devaluing net metering credits was a step in the wrong direction for the Commonwealth. “I’m afraid if we do lower net metering rates by that large amount, it means many solar projects simply will not get built[]”, Hecht said.

With the devaluation of net metering rates, stakeholders will expect the value to be made up elsewhere to ensure the financial viability of solar projects. Following the SREC-II Emergency Regulations issued by the DOER last week, it is clear that the DOER is working on the next phase of the state’s solar incentive program to fulfill their obligations under Section 11 of the Act. Sustainable Energy Advantage, LLC (SEA) has been engaged to assist in conducting analysis in evaluation of the next program, and stakeholders will have the opportunity to participate in the design and implementation of the next phase of the program.

Thanks in large part to the state’s net metering policies, former Governor Patrick setting the state’s 1,600 MW target, and the successful SREC-I and SREC-II programs, the robust Massachusetts solar industry now employs more than 15,100 people. Today, the state ranks sixth in installed solar capacity, with more than 1,020 MW of solar installed.

 

Massachusetts SREC-II Emergency Regulation Filed: April 8, 2016

Posted April 11th, 2016 by SRECTrade.

On Friday, April 8, 2016 (the effective date), the Massachusetts Department of Energy Resources (MA DOER) announced it filed emergency regulation with the Secretary of State’s office. The regulation was submitted to address the current uncertainty in the solar industry and facilitate a smooth transition from SREC-II to the next incentive program. Although this emergency regulation is effective immediately, it can only remain in effect for 90 days pending a full DOER rule-making proceeding. Information on next steps in the emergency regulation process is still forthcoming, including public hearings and public comment submission deadlines.

Notably, the emergency regulation implements the following:

  • Extends SREC-II eligibility to all systems greater than 25 kW constructed by January 8, 2017; 9 months from the effective date
  • Extends SREC-II eligibility to all systems less than or equal to 25 kW interconnected by the start of the next incentive program
  • Implements compliance exemption for all electricity supply contracts signed within 30 days of the effective date
  • Ensures SREC-II will run through 2027

In regard to systems greater than 25 kW, the emergency regulation grants Statements of Qualification dated April 8, 2016, to all systems that have an existing Assurance of Qualification or that have submitted an application. The retention of granted Statements of Qualification is dependent on systems demonstrating (1) authorization to interconnect or (2) proof of construction to the DOER by January 8, 2017.

Reiterating the note above, in regard to systems less than or equal to 25 kW, all applications that demonstrate authorization to interconnect by the start of the next incentive program will be qualified under the SREC-II program.

In close, the DOER noted that development of the Commonwealth’s next solar energy incentive program is underway. Sustainable Energy Advantage, LLC (SEA) has been engaged to assist in conducting analysis in evaluation of the next program. Additionally, the DOER will work with market participants to solicit feedback as the program is designed and implemented.

SRECTrade will continue to monitor the status of the emergency regulation and provide updates regarding the future of Massachusetts’s next solar incentive program. We look forward to watching the state continue to structure competitive market based solutions, similar to those previously utilized, to continue its position as a national leader of deploying distributed solar technologies.