On April 2nd, the Massachusetts Department of Energy Resources (DOER) held a stakeholder meeting in which they presented their straw proposal on the new Clean Peak Standard (CPS) Program. As per the DOER, the program’s primary objective is to “implement a clean peak program that aligns clean energy generation and zero emission demand resources with periods of peak electricity demand in the most cost-effective manner for Massachusetts customers possible while reducing emissions.” To effectively achieve this goal, the program intends to couple the co-deployment of energy storage and renewable resources with demand response resources to help flatten the electric load curve and reduce overall emissions from the electricity sector.

The proposal lays out four separate eligible CPS resources:

1. New RPS Class I resources in operation on or after January 1, 2019
2. Existing RPS Class I/II resources (in operation prior to January 1, 2019) that are paired with an energy storage system
3. Standalone energy storage systems
4. Demand response resources

Eligible resources would be able to generate Clean Peak Certificates (CPCs) during predefined Seasonal Peak Periods. Each season would have a defined, 4 hour daily peak period in which CPCs could be generated. CPCs would be minted on top of any other Renewable Energy Credit (REC) that the asset produces.

The DOER did not provide details on key program metrics and guidelines in their proposal including price support mechanisms, metering requirements, and tracking and verification process. These parameters will be established once the DOER’s contracted consultants provide further analysis support. The DOER requested that stakeholders submit comments on the proposal by April 12th and they plan to release a draft regulation by the end of Q2 2019.

With Q3 2018 issuance numbers out, SRECTrade would like to provide an update on the current standing of the SREC-I and SREC-II markets.

SREC-I 

The SREC-I market is not subject to any new capacity and, as such, is largely impacted by electricity load figures and solar production. Given the current Massachusetts Department of Energy Resources (MA DOER) estimates for exempt load, expected increased retail electric load*, and SRECTrade’s projections for final 2018 SREC generation figures, the 2018 SREC-I market will be undersupplied by approximately 91,000 SRECs, or 10.9% of the exempt load adjusted obligation. Currently, SRECTrade projects the 2019 SREC-I market will have a similar dynamic of undersupply, with a shortage of approximately 46,000 SRECs, or 5.8% of the estimated exempt load adjusted obligation. For specific details, please see our full presentation here.

The market seems to have taken this undersupply into account, with 2018 and 2019 SREC-Is bid at approximately $400 and $370, respectively. These values amount to approximately 94% and 91% of their respective ACP levels ($426 and $404, respectively).

SREC-II

The SREC-II market closed to new capacity as of November 26, 2018. While systems under 25 kW DC must have been interconnected prior to the closing date, applications will still be accepted through February 15, 2019. As such, there is still some uncertainty as to how much additional residential capacity will apply into the program prior to February 15th, although it can be reasonably assumed that this capacity will be marginal. In addition, there exists approximately 80 MW of market factor-adjusted commercial (>25 kW DC) capacity that has received indefinite extensions for the SREC-II program. These systems are mechanically complete and will begin their SREC production once they receive Permission to Operate (PTO) from their respective utility. We assume in our analysis that 90% of these systems will receive PTO within a year of the closure of SREC-II (November 26th) in equal monthly increments, and the remaining 10% will receive PTO after 12 months. This puts our projected final market factor-adjusted SREC-II capacity at 1,534 MW.

Using these assumptions, as well as DOER’s estimates for exempt load, electric load projections, and SRECTrade’s SREC generation forecast, the 2018 SREC-II market will be undersupplied by approximately 145,500 SRECs, or 8.3% of the exempt load adjusted obligation. As it stands, SRECTrade projects the 2019 SREC-II market will be more balanced with a slight oversupply of 7,600 SRECs, or 0.4% of the exempt load adjusted obligation.

The markets have seemingly digested the fact that the 2018 SREC-II market will be undersupplied, bid at approximately $325 or 93% of the ACP ($350). The 2019 SREC-II market has trended upwards in tandem with the 2018 market, however remains split between the SCCA price ($244) and ACP ($333), currently bid at approximately $290. This reflects our projection of a balanced dynamic in 2019.

Should you have any questions about the enclosed analysis or need transaction and management services, please contact us.

*See 2016 MA DOER RPS and APS Annual Compliance Report page 21 for historic and projected retail electric load figures.