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DOER Files APS Regulations with Legislature

Posted October 16th, 2017 by SRECTrade.

On October 13, 2017, the Massachusetts Department of Energy Resources (DOER) filed an amended draft regulation with the Legislature’s Joint Committee on Telecommunications, Utilities and Energy. Pursuant to Chapter 251 of the Acts of 2014 and Chapter 188 of the Acts of 2016, the draft regulations add renewable thermal, fuel cells, and waste-to-energy thermal to the Massachusetts Alternative Portfolio Standard (APS). The filing follows two rounds of public hearing and comment periods occurring in the summers of 2016 and 2017. The draft regulation and accompanying guidelines are available on the DOER’s website here.

In response to stakeholder comments, the DOER made several revisions in the filed regulations. A brief summary of these changes is provided here, but the full redlined version is available for review here.

  • Woody Biomass: revised definitions and requirements, including fuel specification and performance requirements
  • Liquid Biofuels: reorganized quarterly caps to be distributed during each year and aligned requirements for Eligible Liquid Biofuels with the Environmental Protection Agency’s Renewable Fuel Standard (RFS)
  • Compost Heat Exchange Systems: added compost heat exchange systems as an eligible Renewable Thermal Generation Unit
  • Fuel Cells: revised efficiency threshold and modified eligibility for behind-the-meter, electric only, fuels cells to those interconnected to the Massachusetts electric grid
  • Multipliers for Non-Emitting Technologies: added multiplier for compost heat recovery systems and revised multipliers for intermediate and large, partial air source heat pump systems
  • Combination of Funding Provision: removed the combination of funding provisions and increased the maximum combination of funding percentage from DOER or any other state agency to 80%

In addition to the foregoing, the DOER made several technical edits and clarifications to reconcile language inconsistencies in the regulation and Guidelines. The DOER’s announcement of the filing is available here.

SRECTrade will continue to monitor the progress of the APS regulations and will provide updates as they are made available.

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Massachusetts DOER Discusses Final Design to Bring Renewable Thermal into APS

Posted December 19th, 2014 by SRECTrade.

On Tuesday, December 16th the DOER presented a draft of their final design for guidelines pertaining to the inclusion of renewable thermal technologies in the Massachusetts Alternative Portfolio Standard (APS). Per the statute, the DOER will be including technologies that generate useful thermal energy from sunlight, biomass, biogas, liquid biofuel or naturally occurring temperature differences in the ground, air, or water, and has been conducting a comprehensive stakeholder review prior to the formal rulemaking process next year.

While the regulations will likely not go into effect until Summer 2015, the current draft proposes to be retroactive, so that eligible systems installed from January 1, 2015 onwards could qualify for the APS. This is welcome news for renewable technologies such as Solar Hot Water systems, which are not currently included in the state’s Renewable Portfolio Standard (RPS) nor the APS.

Here we will highlight several aspects of the regulation that are especially important for Solar Hot Water installers and owners. Under the proposed draft, eligible solar thermal technologies must be:

– Active solar thermal technology using evacuated tubes or flat place collectors for space heating, domestic hot water, or process hot water.

In terms of the specific registration metering requirements, the draft designates a cutoff between “Small” and “Large” solar thermal systems at surface area of 660 square feet. Larger systems will likely be required to adhere to stringent metering and reporting standards, while small systems will be able to produce Alternative Energy Credits (AECs) based off of the projected output of their system.

In order to reduce the complexity of AEC sales for residential and small commercial owners that fall under the “Small” category of each of these renewable thermal technologies, the DOER is proposing a 10-year upfront strip of AECs in lieu of producing AECs over time. Non-emitting renewable thermal technologies, like Solar Hot Water, would also receive a multiplier on their credits in recognition of their environmental advantage and current higher levelized cost.

Currently the MA APS market is undersupplied, with credits trading in the range of $15-$20/AEC. SRECTrade will continue to follow these regulations closely and keep stakeholders informed on how we will be assisting system owners with AEC transaction and management services.

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Selling SRECs from Solar Hot Water Systems

Posted May 18th, 2012 by SRECTrade.

It’s been a while since we last updated our readers on the fundamentals of SRECs for solar hot water (SHW) systems. Currently two markets, Washington DC and Maryland, allow for SRECs sold from solar hot water systems. There have been proposals to create SREC markets for SHW in other markets, but no other states have concrete plans to do so.

Key concepts:

SRECs from SHW systems are calculated by using the annual energy estimate provided by the Solar Rating and Certification Corporation (SRCC) OG- 300 Water Heating System Rating or by converting BTUs to kW-hr equivalents from BTU meters.  BTU meter readings are provided directly to the tracking registry (PJM GATS) in BTU’s and PJM GATS converts the BTUs into kilowatts.  Calculate kW-hr equivalents by multiplying system BTUs by .000293 and 1,000 kW-hrs = 1 SREC.

Maryland SHW Registration Rules

    • Must be located in MD
    • Only systems commissioned with passing plumbing inspections issued after June 1, 2011 or later are eligible
    • Single dwelling residential systems are capped at 5 SRECs per year
    • Commercial systems are not capped
    • SHW systems cannot be used for heating a pool or hot tub
    • Systems must be certified by the SRCC OG-300 reporting protocol or have an International Organization of Metrology (OIML) compliant meter
    • SHW modules must be SRCC OG-100 compliant

District of Columbia SHW Registration Rules

    • Must be located in DC
    • Residential system must be SRCC OG-300 certified
    • Commercial systems producing >10,000 kW-hr equivalents must be SRCC OG-100 certified and have an OIML compliant meter
    • Commercial systems producing <10,000 kW-hr equivalents must be SRCC OG-100 certified, have an OIML meter or be certified to the SRCC OG-300 reporting protocol

If you’d like to utilize SRECTrade to monetize SRECs produced from SHW systems in either MD of DC please fill out this application and follow the directions on the form.

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MD Solar Thermal Systems Await Application from MD PSC

Posted October 25th, 2011 by SRECTrade.

On January 1st, 2012 the Maryland Public Service Commission (PSC) will begin accepting applications for MD-sited Solar Water Heating Systems (SWH) to become certified to sell SRECs in the MD SREC market. As this law allows eligible systems to be installed on or after June 1, 2011, many MD customers are anxiously awaiting their turn to participate in the MD SREC market. As long as a SWH facility meets the necessary metering standards described in an earlier blog post, the facility can produce SRECs for each MWh-equivalent of thermal energy consumed. For single-dwelling residential systems, there is a maximum 5 SRECs per year that may be produced.

The MD PSC will release the formal application form and list of necessary requirements over the next few weeks. While the MD PSC finalizes their application process, MD SWH systems are encouraged to check out our EasyREC SREC management service and to fill out the SRECTrade Solar Thermal EasyREC form. SRECTrade will guide your system through the registration phase and alert you to any supporting documentation that we will need. Check back on our blog for further updates as we approach the new year.

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MD to Accept In-state Solar Water Heating Systems for SREC Market

Posted May 27th, 2011 by SRECTrade.

Maryland recently passed legislation which will allow residential-scale in-state solar water heating systems (SWH) installed on or after June 1st 2011 to sell SRECs into the MD SREC market.  Eligible systems will, at a maximum, be able to produce 5 SRECs per year. The law does not go in to effect until January 1st 2012, so even if the system is installed now it will be another few months before they can monetize their SRECs. The bill states that eligible SWH systems are those that are not used solely for heating a pool or hot tub and are either metered by a device that meets the standards of the “International Organization of Legal Metrology” (OIML) or be OG-300 certified.

Another requirement is that the SWH collectors (the product that captures the sun’s heat) must be a “glazed liquid-type flat-plate or tubular solar collector by the OG-100 standard of the Solar Ratings and Certification Corporation (SRCC).”

Because SWH systems produce heat and not electricity, output is measured in British Thermal Units (BTUs) and not kW-hrs. In order for these systems to produce SRECs equivalent to their PV-system counterparts, they must be certified and metered in a way that can allow for accurate measuring and unit conversions. By multiplying each BTU by a conversion factor of .000293, one can determine the kWh equivalent production from the system. As a point of reference, a single a 21 ft2 flat plate solar thermal collector located in Baltimore, MD that has a conversion efficiency of 60% may produce as many as 2 SRECs per year.  Conversion efficiencies and BTU output will vary depending on the type of SWH panel used.

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Solar Thermal SRECs in DC – Update

Posted April 12th, 2011 by SRECTrade.

Recent legislation passed by the council of the District of Columbia now allows non-residential solar thermal systems to be registered to produce DC SRECs. Under the new legislation non-residential systems must be SRCC OG-100 certified. The legislation went into effect on March 12, 2011 and will expire on October 23, 2011. Previously the District only accepted SRECs from residential SRCC OG-300 certified solar thermal systems.

The new legislation has the following requirements for solar thermal systems:

Solar thermal non-residential systems producing or displacing more than 10,000 kW-hrs per year must be SRCC OG-100 certified and the annual energy output must be determined by an onsite OIML compliant meter.

Solar thermal non-residential systems producing or displacing 10,000 kW-hrs or less per year must be SRCC OG-100 certified and their annual energy output can be determined by the SRCC OG-300 performance rating protocol OR by an onsite OIML compliant meter.

Residential SRCC OG-300 certified solar thermal systems are not affected by this legislation and can continue to be registered in DC.

Given the current supply dynamics of the DC SREC market, this legislation will continue to provide more supply to the oversubscribed program. While SREC prices could continue to decline in the near term, it may be beneficial for solar thermal system owners, previously not eligible for the DC market, to register and receive certification as an option for potential SREC liquidity.

For an update on the current capacity certified to produce DC SRECs see the SRECTrade SREC Markets Report: March 2011.

Additionally, the Distributed Generation Amendment Act of 2011, could have a positive impact on the oversupplied DC SREC market. The legislation is still pending and details associated with the cut off date for grandfathering in out of state DC registered systems are still unknown. SRECTrade will continue to monitor this piece of legislation and provide additional information as it becomes available. For more background on the proposed amendment see these blog posts:

Could Change Be Coming to Washington DC’s SREC Market?

DC Bill Introduced to Limit Out-of-State Facilities

For information on registering a solar thermal system directly with DC Public Services Commission see this page, or consider registering through SRECTrade’s EasyREC service.

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Solar Thermal SRECs in DC – Update

Posted November 12th, 2010 by SRECTrade.

The Washington D.C. Public Services Commission has recently clarified the requirements associated with registering Solar Thermal facilities to be eligible for the D.C. SREC market.

Moving forward, all eligible systems must be certified by the Solar Rating and Certification Corporation (SRCC). Specifically, the system has to be SRCC OG-300 certified.

The Washington D.C. Public Services Commission has indicated that any changes to the eligibility requirements would have to be made by the legislature, not the public services commission.

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Solar Thermal SRECs in DC

Posted May 13th, 2010 by SRECTrade.

SRECTrade recently began registering solar thermal facilities in Washington DC and North Carolina.  The North Carolina program is in the final stages of being setup and we will provide more information when it is available.  Meanwhile, we’ve already sold our first solar thermal SRECs in the DC market at $290.  Here are some guidelines and information in regards to the requirements to register solar thermal systems in Washington DC:

Are solar thermal SRECs valued the same as solar photovoltaic SRECs sold in auction?
Yes, in DC and NC, solar thermal facilities can be approved to generate SRECs that have the same value to buyers purchasing to meet state compliance requirements.  Any auction for SRECs in DC will include solar PV and solar thermal SRECs sold at the same price.

What if my facility is not eligible in Washington, DC or North Carolina?
Both DC and NC allow out-of-state facilities to qualify, so many states are eligible to sell into these markets.  If your state is not eligible to sell into DC or NC, then the RECs produced by your facility have no value to buyers in the state compliance markets (i.e. our buyers).  You may still however be able to find ways to sell the RECs in voluntary or non-solar compliance markets – also known as generic REC markets.  There are companies out there that may help.

What else should I know about selling SRECs as a solar thermal facility?
Keep in mind the DC SREC market is a relatively small market and could someday be oversubscribed.  We are hopeful that the market for solar thermal SRECs will grow beyond DC as other states follow suit, however, as with any markets, there are risks associated with the market value of SRECs in DC.

What are the requirements for reporting production and generating SRECs?

Residential:
 System must be SRCC-300 rated.  Here’s the link to the approved systems if you don’t already have it: http://securedb.fsec.ucf.edu/srcc/annual_search.  DC will used the energy saved in kWh as your generation for the year.  For example, a 2400 kWh system would receive 200 kWh per month and once the accumulation hits 1000kWh an SREC will be credited to their account

Commercial:
1.  Displaces < 10,000 kWh per year – can use SRCC 300 rating, SRCC-100 panel rating, or use an OIML meter
2.  Displaces > 10,000 kWh per year – must use OIML approved meter

Here are the exact details of the requirements from the Clean and Affordable Energy Act of 2008:

(1) For nonresidential solar heating, cooling, or process heat property systems producing or displacing greater than 10,000 kilowatt hours per year, the solar systems shall be rated and certified by the SRCC and the energy output shall be determined by an onsite energy meter that meets performance standards established by OIML.
(2) For nonresidential solar heating, cooling, or process heat property systems producing or displacing 10,000 or less than 10,000 kilowatt hours per year, the solar systems shall be rated and certified by the SRCC and the energy output shall be determined by the SRCC OG-300 annual system performance rating protocol applicable to the property, by the SRCC OG-100 solar collector rating protocol, or by an onsite energy meter that meets performance standards established by OIML; and
(3) For residential solar thermal systems, the system shall be certified by the SRCC and the energy output shall be determined by the SRCC OG-300 annual rating protocol or by an onsite energy meter that meets performance standards established by OIML.”.

Hopefully this clarifies the solar thermal process in Washington DC.

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