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Massachusetts Governor Baker Releases Net Metering Bill to Rival Senate Bill

Posted August 13th, 2015 by SRECTrade.

Shortly before its summer recess, the Massachusetts Senate passed Amendment 18 to S. 1973 in a voice vote on July 23. Two weeks later, on August 7, 2015, Massachusetts Governor Charlie Baker released a net metering bill to rival S. 1973.

Both the Senate Bill and the Governor’s Bill address the net metering caps that are currently causing a slow-down in the Commonwealth’s solar development, and look to former Governor Patrick’s goal for the Commonwealth to install 1,600 megawatts of solar energy in Massachusetts by 2020. Earlier this year, the Baker-Polito Administration announced its support of the goal to achieve 1,600 MW by 2020. Accordingly, both S. 1973 and the Governor’s Bill propose to raise the net metering caps to meet the goal of 1,600 MW by 2020.

Under Amendment 18 to S. 1973, the Senate calls for raising the caps to 1,600 MW, and eliminating the caps thereafter (the elimination of the caps would apply to solar net metering facilities, with the exception that the maximum amount of generating capacity eligible for net metering by a municipality or other governmental entity shall be 10 megawatts), but the bill would do little else to change the value of a net metering credit. In addition to addressing the caps, the Amendment calls for Massachusetts regulators to “develop a solar incentive program to encourage continued development of solar…” with the goal of “develop[ing] a sustainable long-term framework that effectively balances promoting clean energy and costs to ratepayers,” to be implemented after the 1,600 MW target has been reached. Unfortunately, the Senate bill also attempts to limit the potential options for future programs, without much consideration for allowing the stakeholder process to consider all of the policy options presented by the Task Force in its Final Report (see below).

In contrast, Governor Baker’s Bill would substantially reduce the value of net metering credits in the Commonwealth. For solar projects over 10 kW on single phase, or projects over 25 kW on 3-phase, the value of net metering credits will be the average monthly clearing price in ISO-NE (that is, the wholesale retail rate). This would be a drastic change from the current value, which includes the value of all wires charges, such as distribution, transmission and transition charges. For other specific facilities, including municipal or other governmental entity (“MOOGE”) facilities, facilities for low-income off-takers and community shared solar facilities, the value of net metering credits will be based on the utility’s basic service kW charge, and will also exclude wires charges. The result of this exclusion in both categories is the value of credits being cut nearly in half. But like the Senate Bill, the Governor’s Bill also calls on Massachusetts regulators to “establish a solar incentive program for the development of distributed solar generation beyond 1,600 [MW] by solar photovoltaic facilities connected to a distribution or transmission system, which shall be a statewide program.”

Both the Senate Bill and the Governor’s Bill draw upon the recommendations from the Net Metering and Solar Task Force. The Net Metering and Solar Task Force was a group established last fall by the Massachusetts Legislature under Ch. 251 of the Acts of 2014, Section 7. The Task Force was responsible for reviewing the “long-term viability of net metering and develop recommendations on incentives and programs to support the deployment of 1600 MW of solar generation facilities in the commonwealth.” In its Final Report, the Task Force encouraged the Commonwealth to develop a solar incentive framework that would satisfy eight different program attributes, including promoting the orderly transition to a stable, equitable and self-sustaining solar market, and relying on market-based mechanisms and/or price signals as much as possible to set incentive levels such that the program would be readily adaptable to changing market conditions, all while minimizing costs, incentivizing diverse development, and promoting investor confidence. The Task Force cautiously qualified its recommendations by stating that “[t]he selection of a path for modeling is not an indication that a majority, or indeed any, of the Task Force members would like to see that path implemented,” and encouraged the DOER and DPU to lead a “comprehensive and transparent solar benefit/cost study to determine the value of impact of solar in Massachusetts” so that the Massachusetts Legislature, DOER, and DPU could more thoroughly evaluate the options presented by the Task Force, including the potential for an SREC III program to follow the highly successful SREC I and SREC II programs.

When the Legislature returns from its summer recess this Fall, the Joint Committee on Telecommunications, Utility and Energy will be confronted with the formidable task of reconciling these rival bills alongside the recommendations from the Net Metering and Solar Task Force, in order to help shape the future of solar in Massachusetts.

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MA Department of Energy Resources Update 9/27/13

Posted October 7th, 2013 by SRECTrade.

The Massachusetts Department of Energy Resources (DOER) sent out an email update on Friday, 9/27/13, covering the management of the SREC I program and the status of the DOER proprosal for an SREC II program. The email can be found here.

SREC I Project Deadline Extension Guidelines Drafted

Less than or Equal to 100 KW

Facilities 100 kW or smaller that have submitted a Statement of Qualification application must receive authorization to interconnect by the “effective date of a new solar carve-out program established by the Department, or by June 30, 2014,  whichever is earlier.”*

*We had previously stated that systems 100 kW and smaller must be fully interconnected by December 31, 2013 in order to participate in the SREC I program.

Greater than 100 kW

Facilities greater than 100 kW may be installed no later than June 30, 2014 as long as they are demonstrably 50% complete by December 31, 2013.

The DOER is accepting comments on the draft guidelines through Monday, 10/7/2013.  Comments may be sent to doer.srec@state.ma.us with the “Solar Construction Guideline Comments” in the Subject field. The DOER’s draft guidelines can be found here.

SREC II Technical Session

The DOER will hold a technical session on Monday, 10/7/2013 to discuss the SREC II proposal with a team of consultants that the DOER has employed to “conduct studies in support of the SREC II program design.” This team of consultants is charged with creating five reports in support of an SREC II program. Two of the five reports are published and available here.

Technical Session Details:

Monday, 10/7/2013 from 1-3 pm
Gardner Auditorium, Massachusetts State House
Boston, MA
 

2012 Solar Credit Clearinghouse “Last Chance Auction” SREC Purchase Results

Only three SRECs of the 38,863 SRECs deposited in the 2012 Solar Credit Clearinghouse Auction (SCCA) were purchased during the auction. Following the auction the DOER offered to purchase all available 2012 vintage SRECs for $285/SREC. The DOER announced that they purchased 36,437 SRECs, leaving 2,426 MA2012 SRECs in the market.

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Massachusetts Announces the 2014 Compliance Obligation and SREC II Program Meeting Date

Posted July 25th, 2013 by SRECTrade.

Less than 24 hours before the start of the DOER Solar Credit Clearinghouse Auction (SCCA), referenced here and officially here, the Massachusetts DOER announced the preliminary SREC compliance obligation for 2014. The DOER’s original email can be found here.

A quick look at the numbers

The official 2014 SREC requirement is 498,951 SRECs, however 4,369 SRECs are deducted from the overall requirement because of a settlement between TransCanada, a power supplier, and the DOER. This gives us a final number of 494,582 SRECs required. If the SCCA goes to the 3rd round, the 2014 compliance obligation will automatically increase by the volume deposited, 38,866 SRECs, resulting in a new 2014 net compliance obligation of 533,448 SRECs.

Approximately how much more solar is needed in 2014 

According to the DOER’s calculation worksheet, 245.9 MW of capacity is currently qualified (installed through July 25). In simple terms, the 2014 compliance requirement equates to an average of 426.4 MW or 459.9 MW operational all year long to mint the 494,582 or 533,448 MWh requirements (note the 2 scenarios depend on whether or not the the upcoming SCCC reaches the 3rd round). Also, its important to note that the MW equivalent figures only take into consideration SRECs issued during the 2014 compliance year. We already know there is excess supply from 2012, the volume banked and deposited into the SCCA, and oversupply from 2013 that will effectively reduce the capacity needed online throughout 2014 to meet the Solar RPS requirements.

The difference between the 245.9 MW qualified and the capacity needed under each 2014 scenario is a difference of 180.5 MW or 214.0 MW. Given the recent qualified and pending SQA lists, there are approximately 435 MW eligible but not yet operational. This means that approximately 40-50% of the eligible, not operational capacity would need to be installed by 12/31/2013 (without including oversupply from previous periods) to have enough solar capacity, by the beginning of the year, issue the 2014 MA SRECs required.

Timeline for large project installations

Projects that are greater than 100 kW in capacity and eligible for the current program must be operational by 12/31/13 or demonstrate that they have expended at least 50% of the project costs before the end of the year to receive an extension until the end of June 2014. Projects that can demonstrate substantial delays originating from the interconnecting utility can possibly receive longer extensions. This means that it will be at least until the end of the year, if not June 2014, before we understand the final shake out of installed capacity eligible under the current SREC program.

SREC II Program Meeting

The DOER will hold a stakeholder meeting to discuss the next SREC program on August 12th from 1 to 3 pm ET. The meeting will be held in the Gardner Auditorium of the Massachusetts State House in Boston. Further information on the SREC II program can be tracked here. The email announcing the meeting is linked here.

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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.

 

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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.

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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.

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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.

 

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Massachusetts SREC Webinar Posted to YouTube

Posted December 6th, 2012 by SRECTrade.

SRECTrade hosted a webinar on Wednesday, 12/5/2012. You may watch the webinar by clicking on this link.  The webinar covers the status of the Massachusetts SREC Program, an update on SRECTrade’s services, an analysis of the SREC market moving forward and some best practices on getting solar installations registered to create Massachusetts Solar Renewable Energy Certificates.

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MA DOER Releases 2012 SREC Requirement

Posted September 5th, 2011 by SRECTrade.

The Massachusetts Department of Energy Resources (DOER) recently announced the SREC requirement for the 2012 compliance year. The 2012 compliance requirement is based on a formula that takes into consideration the 2011 compliance obligation, the forecast 2011 total SREC generation, and the actual 2010 SREC generation. A growth rate is then applied to these figures based on a set formula for the MA SREC program. Additional considerations are made for the 2010 Alternative Compliance Payment (ACP) volume, the 2010 banked SREC volume, and the number of 2010 SRECs purchased through Solar Credit Clearinghouse Auction. For a detailed analysis of this formula and the considerations made for setting the 2012 requirement please see this link.

Upon running the figures, the DOER arrived at a 2012 compliance obligation of 81,559 MWhs or SRECs. This represents an increase over the 2011 standard by 2,982 SRECs, or approximately 3.8%. After factoring in the estimated load exemptions from the TransCanada settlement, the 2012 compliance year target is approximately 73,400 SRECs. This equals an increase of approximately 10,400 SRECs from the 2011 adjusted target of about 63,000 SRECs. Converting these figures to MW capacity, using a 1.13 MWh production factor per installed kW per year, 2012 will need the equivalent of approximately 65 MW online vs. the 2011 required capacity of approximately 55.7 MW. This step up in capacity represents an increase of 16.6%.

MA 2012 Capacity Req Graph

*Note: The 2011 and 2012 estimated megawatts required in the chart above have been adjusted for the impact of the TransCanada settlement.

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Solar Capacity in the SREC States – August 2011

Posted August 26th, 2011 by SRECTrade.

SRECTrade SREC Markets Report: August 2011

The following post outlines the megawatts of solar capacity certified and/or registered to create SRECs in the SREC markets SRECTrade currently serves.

For a PDF copy of this table click here.

Renewable Generators in GATS 8_25_11_v4

PJM Eligible Systems

As of the end of August, there were 18,112 solar PV (17,791) and solar thermal (321) systems registered and eligible to create SRECs in the PJM Generation Attribute Tracking System (GATS) registry. Of these eligible systems, 77 (0.43%) have a nameplate capacity of 1 megawatt or greater, of which only 6 systems are greater than 5 MW. The largest system, currently located in New Jersey, is 18.3 MW, and the second largest, located in Ohio is 12 MW. The third largest system, at 11.2 MW, is located in Delaware.

Beginning of energy year for DE, NJ, and PA

June 1, 2011 marked the beginning of the new energy year for DE, NJ, and PA. All requirements for these markets increase given their RPS solar carve out schedules. SRECs for the month of July, the second creation period for the new reporting year, will be minted at the end of August.

Delaware: The reporting year 2011-2012 requirement for DE equates to approximately 21 MW being online for the entire year or approximately 25,600 SRECs created. As of August 25, 2011, 20.5 MW of solar capacity was registered and eligible to create DE SRECs in PJM GATS. 11.2 MW of the 20.5 MW currently eligible is from the Dover Sun Park project developed by LS Power. In the 2011-12 compliance year, Delmarva Power has contracted to purchase 9,846 SRECs from the project, of which 7,000 are being held by the Sustainable Energy Utility (SEU) until 2015-16*.

New Jersey: The reporting year 2012 requirement for NJ equates to approximately 368 MW being online for the entire year with a fixed SREC requirement of 442,000 MWhs. As of August 25, 2011, 379 MW of solar capacity was registered and eligible to create NJ SRECs in PJM GATS. While this figure represents all projects registered in GATS, there are recently installed projects awaiting issuance of a New Jersey state certification number. This delay results in a portion of installed projects not yet represented in the 379 MW figure. On July 26, 2011 the NJ Office of Clean Energy (NJ OCE) reported that as of June 30, 2011 more than 380 MW (10,086 projects) of solar had been installed in NJ. The news release noted that 40 MW were installed in the month of June. The installation data for July 2011 has not yet been released by the NJ OCE. For more details on the the current NJ market conditions see this post.

Pennsylvania: The reporting year 2012 requirement for PA equates to approximately 44 MW being online for the entire year or approximately 53,000 SRECs created. As of August 25, 2011, 124.5 MW of solar capacity was registered and eligible to create PA SRECs in PJM GATS.

Massachusetts DOER Qualified Projects

As of August 15, 2011, there were 861 MA DOER qualified solar projects; 829 operational and 32 not operational. Of these qualified systems, 11 (1.3%) have a nameplate capacity of 1 megawatt or greater, of which only 3 are between 1.5 and 2 MW. Three of the projects greater than 1 MW are currently operational.

Capacity Summary By State

The tables above demonstrate the capacity breakout by state. Note, that for all PJM GATS registered projects, each state includes all projects certified to sell into that state. State RPS programs that allow for systems sited in other states to participate have been broken up by systems sited in state and out of state. Additional detail has been provided to demonstrate the total capacity of systems only certified for one specific state market versus being certified for multiple state markets. For example, PA includes projects only certified to sell into the PA SREC market, broken out by in state and out of state systems, as well as projects that are also certified to sell into PA and Other State markets broken out by in state and out of state systems (i.e. OH, DC, MD, DE, NJ). PA Out of State includes systems sited in states with their own state SREC market (i.e. DE) as well as systems sited in states that have no SREC market (i.e. VA). Also, it is important to note that the Current Capacity represents the total megawatts eligible to produce and sell SRECs as of the noted date, while the Estimated Required Capacity – Current and Next Reporting Year represents the estimated number of MW that need to be online on average throughout the reporting period to meet the RPS requirement within each state. For example, New Jersey needs approximately 368 MW online for the entire 2012 reporting year to meet the RPS requirement. Additionally, the data presented above does not include projects that are in the pipeline or currently going through the registration process in each state program. This data represents specifically the projects that have been approved for the corresponding state SREC markets as of the dates noted.

*Source: State of Delaware Pilot Program For the Procurement of Solar Renewable Energy Credits: Recommendations of the Renewable Energy Taskforce

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