Archive for the ‘Massachusetts’ Category

Massachusetts DOER 400 MW Cap Stakeholder Meeting

Posted June 7th, 2013 by SRECTrade.

Today, the DOER hosted a meeting to address how the current SREC program will be finalized and the implementation of a the state’s next SREC program. The MA SREC market was thrown a curve ball last week when the DOER announced on May 29th that the current SREC program had reached its 400 MW capacity. Many industry participates expected the program to be closed to applicants sometime in 2014. In fact, the DOER planned to announce on June 7th, a process for applicants to ensure project eligibility under the current 400 MW SREC program.

The meeting today outlined the criteria for managing projects that are installed but not listed as eligible under the original application guidelines for the current program and those projects that have applied but are not yet installed.

In addition to today’s meeting, the DOER promulgated rule changes proposed in February of this year (see blog post here). The details of the implemented rules can be found on the DOER’s website here.

Clarifications on project eligibility for the current SREC program

The DOER plans to enact emergency rules for the current 400 MW Solar Carve-out program. The initial outline of those rules are listed below and additional details can be found here on the DOER’s website. A link to the presentation slides from today’s meeting can be found here. We will update updates on these rules as the DOER provides further official clarification.

The DOER is expanding the current program capacity limit to include project applications that meet certain criteria. To do this this they are splitting applications up into two categories based on facility size: 1) projects equal to or less than 100 kW and 2) projects greater than 100 kW.

Projects equal to or less than 100 kW

  • Applications for facilities equal to or less than 100 kW which have an authorization to interconnect approval and have submitted an SQA prior to the effective date of MA’s next solar carve-out program will be provided an SQA. We believe the effective date will be 1/1/2014 at the earliest, but look to the DOER to provide further clarification.

Projects greater than 100 kW

  • Projects that are listed after the 400 MW capacity cap demarcation on the pending SQA list will qualify if they they meet the following criteria: 
    • Fully executed Interconnection Service Agreement (ISA) application dated June 7, 2013 or earlier.
    • Receive an authorization to interconnect by 12/31/2013, or an extension to 6/30/2014 can be applied for if at least 50% of the project budget is spent by 12/31/2013.
    • Projects that can demonstrate interconnection applications have been delayed by the distribution utility can request further extensions. 

Clarifications on the next SREC program

The DOER indicated that the next phase of the Massachusetts SREC market will be a modification of the current program. The Commonwealth has an overall goal of 1,600 MW of installed solar capacity under the current SREC program and the future SREC program. The final size of the next SREC program will be determined by how many facilities meet the criteria for eligibility outlined above for the current program. For example if 500 MW of capacity is approved in the current program, then the next SREC program will allow for 1,100 MW of eligible capacity. The DOER emphasized that the next program’s design will take in to account a goal to minimize the impact of the program on rate rate payers and eventually bring the SREC market in line with the Massachusetts Class I REC market.

To do this the DOER plans to implement a series of key design features based on project location, size, and a new tool that the DOER calls the Adjusted SREC factor. Smaller projects will be granted SRECs that carry an inherently higher value than larger projects. Additionally, it was proposed that a greater SREC factor will be given to projects installed on brownfields and other specially designed zones. The DOER intends to adjust the SREC factor over time for projects as more capacity comes to market and the cost to install decreases.

The DOER also intends to moderate growth by capping the capacity for eligible project applications on a year to year basis using managed growth provisions to throttle supply.

The DOER mentioned that a separate, but similar Solar Credit Clearinghouse Auction will provide a price support mechanism. All projects will have a 10 year opt-in term. The price set under this mechanism was not mentioned. The DOER did indicate that it is waiting for the legislature to determine the outcome of H2915, a bill that if passed, would require the distribution utilities to support a minimum SREC price in years where there is an over-supply of SRECs.

Preliminary SACP prices were presented as well. The SACP is the penalty price that electricity suppliers in the MA market must pay if they do not meet their renewable energy compliance requirement with SRECs. The proposed schedule is listed below:

2014: $375
2015: $350
2016 (and beyond): $325

We look to the DOER to continue to clarify the application rules for the current SREC program as well as the general market design and implementation period for the next SREC program. We express some concern over the administrative complexities presented by the proposed SREC II program. It is important that the DOER and stakeholders understand that however the new program is structured, participants should focus on pursuing administrative efficiency in transacting SRECs and managing solar assets. SRECTrade will stay in close touch with the DOER and continue to provide updates on this blog.

 

Massachusetts 400 MW Cap Update

Posted June 3rd, 2013 by SRECTrade.

DOER to file emergency regulation

On Monday evening (6/3/2013) the DOER sent out a second email updating stakeholders on the situation surrounding the state’s solar requirements surpassing the current 400 MW goal. The email included a link to the latest data on the status of projects’ applications for the 400 MW Solar Carve-out. Additionally, the statement noted the DOER’s intentions to file emergency regulation sometime this month. Details on the emergency regulation proposal will be provided at a stakeholder meeting this Friday, June 7th. In addition to the emergency regulation, the meeting will cover the status of the post 400 MW solar program.

400 MW Solar Carve-out filled with non-operational project applications

On May 29th SRECTrade reported on an email from the Massachusetts DOER stating that the Massachusetts SREC market had reached the 400 MW goal. This came on the heels of a May 20, 2013 qualified projects list released by the DOER that showed only 287 MW of qualified capacity registered, which left room for 113 MW of new qualified capacity. Of the 287 MW capacity, 69.1 MW was listed as non-operational. However, the Pending SQAs list made public today shows that an additional 110.8 MW of non-operational projects were listed as qualified or administratively complete by the DOER between the issuance of the 2 reports. In total 179.9 MW or 45% of the qualified or administratively complete solar capacity is currently listed as non-operational.

SRECTrade to attend the DOER’s stakeholder meeting on June 7th

SRECTrade continues to closely monitor events and will have a representative at the DOER’s stakeholder meeting on Friday, June 7th. We will provide any relevant updates as they become available.

MA DOER Solar Stakeholder Update – 400 MW Cap

Posted May 29th, 2013 by SRECTrade.

The MA DOER sent out an email on Wednesday, May 29th to MA solar stakeholders announcing that more than 400 MW of SREC program applications are now administratively complete. The email can be read here. In total 550 MW of applications have either been qualified or are under review. The most recent data released (5/20/2013) by the DOER shows that 217.9 MW of applications are qualified and operational, suggesting that over 180 MW of capacity is qualified and not yet operational.

Below are the key points:

  • The DOER will announce the rules for a new 1,200 MW capacity program shortly.
  • 550 MW of capacity has applied for an SQA under the current 400 MW program.
  • Approximately 400 MW is defined as administratively complete.
  • The DOER will announce no later the June 4th a current list of all projects that have or will receive a Statement of Qualification. It will also post a list of projects, in order of their eligibility for qualification, that have SQAs deemed administratively complete but are beyond the 400 MW cap of qualified capacity, as well as a list of pending applications under review.
  • The DOER will continue to accept applications and allow two weeks for applicants to address any deficiencies before rejecting the applications. The DOER expects that applications received on or after June 7th, the anticipated promulgation date of the new regulation, will be reviewed under the revised regulation.
  • Some of the non-operational administratively complete and incomplete SQA applications are likely to be rejected or otherwise taken out of the application queue by project owners that are not yet prepared for construction.

What SRECTrade is doing

SRECTrade will continue to process applications with the DOER pending any clarification that applications will not be accepted. All applications that have been submitted to SRECTrade for SQA paperwork have been submitted to the DOER and will be finalized under the normal procedures. Further clarifications will be sent to our clients and partners as the DOER releases more information. Until then we will remain diligently attuned to any news from the DOER and other stakeholders.

What is the 400 MW Cap?

400 MW of installed PV capacity in Massachusetts is eligible for the current Massachusetts SREC program. Projects that are deemed eligible by the DOER to participate in the current program are allowed 40 quarters from their eligibility start date (defined by their SQA application) to produce SRECs and qualify for DOER Solar Credit Clearinghouse Auctions. Projects that are installed and registered after the 400 MW cap is reached will be eligible for another program that the DOER will outline shortly.

MA DOER Solar Industry Stakeholder Update

Posted May 23rd, 2013 by SRECTrade.

Today, the Massachusetts Department of Energy Resources (MA DOER) sent a notice to MA Solar Industry stakeholders. The email addressed the following subjects:

    1. Post-400 MW Solar Policy Development – Stakeholder Meeting, June 7th: The DOER will host a public stakeholder meeting on Friday, June 7, 2013 from 10 a.m. to 12 p.m. in the Gardner Auditorium of the State House in Boston. The DOER will present its proposed policy for the post-400 MW solar program.
    2. Solar Credit Clearinghouse Auction – Account is Open for Deposits and an Auction will be Held: The Solar Credit Clearinghouse Auction account is open for deposits. Deposits must be made by June 15, 2013. All clients utilizing SRECTrade’s EasyREC asset management services will have any unsold MA2012 SRECs automatically deposited into the auction account. The first round of the auction is scheduled to be held on July 26, 2013.
    3. Assurance of Qualification Guideline – Revised Draft now posted for comments: The DOER posted revisions to the qualification guidelines. This document clarifies the queuing and review process as the 400 MW Solar Carve-Out program cap is approached.

To see the original notice click here. SRECTrade will continue to provide any relevant updates on these subjects as more information becomes available.

May 15, 2013 Massachusetts SREC Webinar Posted

Posted May 21st, 2013 by SRECTrade.

SRECTrade recorded a webinar on May 15, 2013. The webinar covered the following topics:

  1. SREC prices and supply
  2. Massachusetts SREC policy
  3. The DOER SREC auction
  4. SRECTrade asset management and brokerage services

Please click this link to view the webinar recording. 

About the speakers

Steven - mug
Steven Eisenberg is the Vice-President of Business Development. Steven has been with SRECTrade since 2010 and is responsible for starting and managing SRECTrade’s growing brokerage and institutional SREC asset management business units.
Alex mug
Alex Sheets comes to SRECTrade from SunEdison. As SRECTrade’s Director of Environmental Markets, Alex assists buyers and sellers in originating, executing, and negotiating SREC transactions in the over the counter markets.
sam's resized headshot
Sam Rust is the Director of Business Development and Channel Operations, a role he has been in since 2011. Sam focuses on working with SRECTrade’s installer partners and commercial clients.

 

Massachusetts DOER Fixes Opt-In Term at 40 Quarters

Posted May 2nd, 2013 by SRECTrade.

The Massachusetts Department of Energy Resources (DOER) is expected to announce via a general email that they will forego the much anticipated DOER Solar Credit Clearinghouse Auction eligibility step down requirement for  systems registered after a certain date this year. Previously the DOER had stated that applications must be submitted by either June or July (the deadline was recently pushed to July 15th) in order to be eligible for the DOER Solar Credit Clearinghouse Auction for 40 quarters worth of SREC production.

This adjustment has a few obvious implications. The market will now last longer (40 quarters from the date that the 400th MW is installed) and all systems will have 40 quarters of eligibility from the date that they begin their SREC production eligibility. All solar facilities registered in the current version of the Massachusetts SREC market are limited to 40 quarters of Opt-In eligibility. This announcement does not imply that existing solar facilities now have more time to produce SRECs that are eligible for the DOER Solar Credit Clearinghouse Auction.

In Massachusetts SRECs are created on a quarterly basis and the DOER Solar Credit Clearinghouse Auction is viewed as a price support mechanism for the stability of SREC prices. The DOER Solar Credit Clearinghouse Auction goes in to effect in years where there are more SRECs available to the market than are required by the state’s Renewable Portfolio Standard (RPS). In previous trading years the market was under-supplied. The 2012 trading year is the first over-supplied year for Massachusetts SRECs and approximately 45,000 SRECs will be deposited in the inaugural DOER Solar Credit Clearinghouse Auction. For those  clients using SRECTrade’s asset management services, EasyREC, SRECTrade will automatically transfer any unsold SRECs to the DOER Solar Credit Clearinghouse Auction account. No action is required by clients utilizing this service. To learn more about the current state of the market and the upcoming DOER Solar Credit Clearinghouse Auction click here.

SRECTrade will continue to post updates on this topic as more information becomes available.

Massachusetts Market Update Webinar

Posted April 24th, 2013 by SRECTrade.

MA SREC Webinar May 15 2013SRECTrade will host a webinar covering the Massachusetts SREC market on Wednesday, May 15, 2013 at 2 pm ET. The webinar will cover the rules and timeline for the DOER Solar Clearinghouse Auction.  Additionally, information provided by the DOER concerning applications eligible for the current 10 year opt-in term will also be reviewed. Lastly, as the program’s 400 MW cap is approached, the DOER will be implementing queuing and registration requirements. These intricacies will also be discussed. To register for the webinar please follow this link. The webinar recording will also be posted to SRECTrade’s blog.

Massachusetts Post-400 MW Solar Program Proposal

Posted April 22nd, 2013 by SRECTrade.

Some projections show installed PV capacity eligible for the MA Solar Carve-Out Program, otherwise known as the MA SREC program, reaching 400 MW as early as 2014. Once the current SREC market reaches 400 MW no other projects will be eligible for participation in the current program. In preparation for the approach of the 400 MW cap, the DOER held a “Post-400 MW Solar Policy Stakeholder Meeting” in Boston on March 22, 2013, attended by SRECTrade’s own Alex Sheets.

The purpose of the meeting was to discuss the DOER’s post-400 MW program proposals, including the need for additional clarifications on an “Assurance of Qualification” queuing process for projects wishing to participate in the current iteration of the SREC program. After the meeting’s conclusion, the DOER requested additional formal comments and suggestions. The DOER has since issued guidance on Assurance of Qualification process as well as public comments on the size and shape of a solar incentive program after the 400 MW cap is reached for the current program.

Assurance of Qualification Guideline

In its April 12, 2013 email the DOER summarized the main points of its draft Assurance of Qualification (queuing process) proposal. The draft guideline can be viewed here and we reprint the DOER’s own draft bullet points here:

  • Establishes a list of criteria for determining what constitutes a “complete” application.
  • Creates an exception for small generation units (<30kW DC) that exempts them from meeting the same criteria that larger projects must meet in order to qualify.
  • Establishes a set-aside of the 400 MW DC program cap specifically for small generation units that is equal to 60 MW DC. This 60 MW set-aside includes just over 30 MW of small generation units that are already qualified and operational and helps ensure that the residential and small commercial sector will be protected from any market disruptions in the event the 400 MW program cap is reached before a new program is in place.
  • Establishes a reservation period of 9 months for projects that have obtained an Assurance or Statement of Qualification. Units must be interconnected within this reservation period or will lose their Assurance or Statement of Qualification. It also provides for extensions of this reservation period in certain situations.
  • Creates a list of permissible and prohibited changes that can be made to a project after it receives its Assurance or Statement of Qualification.

Post-400 MW Solar Policy Proposals

The DOER posted all written proposals for a post-400 MW program here. A wide spectrum of proposals were submitted. However, suggestions predictably ranged from the implementation of a feed-in-tariff program to the development of a parallel SREC program, similar to the current one. In general it appears that the majority of stakeholders support the continued implementation of an SREC-based policy.

SRECTrade will continue to closely monitor the development of both post-400 MW policy as well as the Assurance of Qualification process and will periodically update this blog with updates.

 

 

Massachusetts DOER Clearinghouse Auction Update

Posted April 19th, 2013 by SRECTrade.

The Massachusetts SREC market is unique among SREC markets in that it is underlain by a price support mechanism called the DOER Solar Credit Clearinghouse Auction. The DOER Solar Credit Clearinghouse Auction is held no later than July 31st in years in which SRECs are deposited into the DOER auction account. The rules of the MA SREC market require that unsold SRECs be placed in the DOER auction account by June 15, 2013. SRECs placed in the DOER’s auction are sold at a set price of $285/SREC, after DOER administrative fees.

The DOER Solar Credit Clearinghouse Auction does not require buyers to participate and purchase SRECs for any volume, but a variety of compliance incentives encourage participation. For this reason, market participants view the price support attributes of the DOER auction with caution. There is no guarantee that SRECs placed in the DOER auction will be sold.  After multiple rounds of the auction, if any unsold SRECs remain they are transferred back to the original owner. These unsold SRECs, now no longer eligible for future DOER auctions, are reissued with a new useful life in the following three compliance periods. For example, a 2012 SREC not sold in the July 2013 DOER auction will be reissued to the original owner with eligibility in 2013, 2014, and 2015. This reissued SREC must be transacted in one of these three compliance periods.

The MA SREC market is over-supplied for the first time in the short history of the MA solar program (the MA SREC market started in 2010). There are approximately 45,000 more MA2012 SRECs available than are required, all of which will likely be deposited in the DOER Solar Credit Clearinghouse Auction. All client’s utilizing SRECTrade’s EasyREC services will have any unsold MA2012 SRECs automatically transferred into the DOER auction account. Any sellers managing their own NEPOOL GIS account should know that their SRECs need to be manually transferred to the DOER auction account on or before June 15, 2013. For instructions on how to do so click here.

Massachussetts DOER Auction 40 Quarter Opt-In Deadline Now July 15th

Posted April 18th, 2013 by SRECTrade.

The Massachusetts Department of Energy Resources (DOER) sent out a general letter on April 12, 2013 clarifying the deadline for submitting an application to guarantee the 10 year/40 Quarter DOER Auction Opt-In Term. The new deadline is July 15, 2013. SRECTrade had originally communicated that the deadline was June 20, 2013 based on previously provided DOER information. SRECTrade will be be able to process EasyREC applications for the 10-year Opt-In Term if submitted by July 1, 2013. The earlier an application is submitted, the easier it will be to ensure that applications are processed in a timely fashion. We encourage early submission of applications.

Successful acceptance into the 10 year/40 Quarter DOER Auction Opt-In term begins upon the statement of qualification date. For example, if a project is accepted in Q3 2013, but not interconnected until Q1 2014, the project will forego 2 quarters (i.e. Q3 and Q4 2013) of DOER auction eligibility.

What is required to submit an application that qualifies for the 10 year Opt-In Term?

  • Completed EasyREC application (without letter of interconnection)
  • Must be submitted to SRECTrade before July 1, 2013
  • Proof of applicable state and local permits is required for projects greater than or equal to 1 MW