In recent months, the Washington D.C. SREC market has seen a relative lack of liquidity compared to prior compliance years and a resulting downward impact on pricing. This dynamic has developed as a result of the Renewable Portfolio Expansion Act of 2016, which allowed for electricity load signed under contract prior to October 8, 2016 to be grandfathered under the old Solar Alternative Compliance Penalty (SACP). With the current Calendar Year 2018 (CY2018) SACP at $500/MWh and the old CY2018 SACP at $300/MWh, electricity suppliers with grandfathered load have opted to pay the lower SACP fee instead of purchasing SRECs for each MWh of compliance associated with load under a grandfathered contract. As such, effective SREC demand has been temporarily reduced.
In CY2017, 28.8% of the compliance obligation was met through retirement of DC-eligible SRECs. This implies that 71.2% of the compliance obligation was met through SACP payments and, correspondingly, 71.2% of 2017 load obligation was grandfathered under the old SACP. Details of this can be found in the DC Public Service Commission’s Report on the Renewable Energy Portfolio Standard for Compliance Year 2017 (see pages 15-17 specifically). With each subsequent year up through 2021, a portion of this load will roll off of contract, incrementally increasing SREC demand. The enclosed analysis assumes that these contracts will roll off in equal intervals each year over the next three years. As such, the analysis assumes that beginning in CY2020, there will be no load remaining under a grandfathered contract. While this may not be the case (since it is possible there were five year load contracts signed in 2015/2016), we assume that the majority of grandfathered contracts have a three year term and will expire by CY2020.
Reflective of the $200 difference between the previous program’s and current program’s SACP for CY2018, the price of SRECs have decreased from $470 in February 2017 to approximately $370 in July 2018. Under our assumption, approximately 40% of electric load remains under grandfathered contracts for CY2018. We can gather from this statistic that approximately 40% of compliance from CY2018 will be met through SACP payments and the remainder will be met through the purchase of SRECs. The enclosed analysis demonstrates a likely oversupply in the current 2018 compliance year. At current build rates of 1.14 MW/month, the market would be approximately 30% oversupplied in 2019, nearly balanced in 2020, and move to a state of under supply in 2021, 2022, and 2023. The presentation also demonstrates the expected supply relative to RPS solar demand at greater build rates from the last twelve month average.
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