SRECTrade will be hosting a webinar this Tuesday, December 13th, at 2:00 PM EST. The webinar will cover the current state of the Massachusetts SREC-II program, key deadlines for qualifying systems under SREC-II, and SRECTrade application processes to consider as the program’s close approaches.
To attend the webinar click HERE to register. A recording will be made available on SRECTrade’s blog for those unable to attend.
TweetToday, the Massachusetts Department of Energy Resources (DOER) announced that both of the 2015 Solar Carve-out (SREC-I) and Solar Carve-out II (SREC-II) auctions have fully cleared in the first round.
Preliminary results for the SREC-I auction included 41 unique bidders submitting a total bid volume of 49,886 – more than sufficient demand to clear the available auction volume of 1,898 SRECs. Similarly, the results for the SREC-II auction included 9 unique bidders submitting a total bid volume of 112,252, which cleared the available auction volume of 67,046 SREC-IIs.
The DOER and EnerNOC continue to certify and finalize the auction results, and will publicize more details on the final results on the SREC-I and SREC-II auction webpages next week.
TweetFriday, July 22, 2016, the Massachusetts Department of Energy Resources (DOER) announced the preliminary 2017 Solar Carve-out (SREC-I) and Solar Carve-out II (SREC-II) Compliance Obligations and Minimum Standards. Customarily, the DOER estimates these values prior to administering the Solar Credit Clearinghouse Auction each year. The final 2017 Minimum Standards will be announced on or before August 30th, after both the SREC-I and SREC-II Auctions have concluded.
Solar Carve-out (SREC-I)
Notably, the DOER projects that the final 2017 Compliance Obligation for the SREC-I program will be approximately 783,181 MWhs and that the Minimum Standard will be approximately 1.6313%. These values will be increased to 785,077 MWhs and 1.6352%, respectively, if the SREC-I auction does not fully clear in the first two rounds. The 2017 Minimum Standard for load under contracts signed before June 28, 2013 will be 0.9861%.
The DOER published a resource outlining its calculation of the preliminary SREC-I Minimum Standard.
Solar Carve-out II (SREC-II)
Regarding the SREC-II Program, the DOER established a baseline Compliance Obligation and Minimum Standard that would have applied to Retail Electricity Suppliers had the RPS Class I Emergency Regulation not been filed on April 8, 2016; these suppliers are exempt from any additional obligations resulting from the expansion of the SREC-II Program Capacity Cap.
To calculate this baseline Minimum Standard, the DOER first determined the expected MWh/year that would have resulted had the SREC-II Program Capacity Cap remained 947 MW by:
The DOER then summed these values and combined the auction volume and banked SREC-II volume from the 2015 Compliance Filings, resulting in a baseline Compliance Obligation of 1,102,311 MWhs and a Minimum Standard of 2.2960%. These values will be increased to 1,169,357 MWhs and 2.4357%, respectively, if the SREC-II auction does not fully clear in the first two rounds.
Additionally, the DOER calculated the preliminary 2017 SREC-II Compliance Obligation and Minimum Standard for load under contracts signed after May 8, 2016 – 1,496,188 MWhs and 3.1164%, respectively. These values will be increased to 1,563,234 MWhs and 3.2561% if the SREC-II auction does not fully clear in the first two rounds.
The DOER also published a resource outlining its calculation of the preliminary SREC-II Minimum Standard.
Solar Credit Clearinghouse Auctions
The first rounds of the SREC-I and SREC-II Solar Credit Clearinghouse Auctions are scheduled for July 29, 2016. A second and third round will be held as needed the following week should these auctions not fully clear.
The DOER has also provided slight updates to the volumes of SRECs available in the Auctions: 1,896 in SREC-I and 67,046 in SREC-II.
SRECTrade will continue to monitor the proceedings of the Solar Credit Clearinghouse Auctions and will report the outcomes of the Auctions once the results become readily available.
TweetOn Friday, April 8, 2016 (the effective date), the Massachusetts Department of Energy Resources (MA DOER) announced it filed emergency regulation with the Secretary of State’s office. The regulation was submitted to address the current uncertainty in the solar industry and facilitate a smooth transition from SREC-II to the next incentive program. Although this emergency regulation is effective immediately, it can only remain in effect for 90 days pending a full DOER rule-making proceeding. Information on next steps in the emergency regulation process is still forthcoming, including public hearings and public comment submission deadlines.
Notably, the emergency regulation implements the following:
In regard to systems greater than 25 kW, the emergency regulation grants Statements of Qualification dated April 8, 2016, to all systems that have an existing Assurance of Qualification or that have submitted an application. The retention of granted Statements of Qualification is dependent on systems demonstrating (1) authorization to interconnect or (2) proof of construction to the DOER by January 8, 2017.
Reiterating the note above, in regard to systems less than or equal to 25 kW, all applications that demonstrate authorization to interconnect by the start of the next incentive program will be qualified under the SREC-II program.
In close, the DOER noted that development of the Commonwealth’s next solar energy incentive program is underway. Sustainable Energy Advantage, LLC (SEA) has been engaged to assist in conducting analysis in evaluation of the next program. Additionally, the DOER will work with market participants to solicit feedback as the program is designed and implemented.
SRECTrade will continue to monitor the status of the emergency regulation and provide updates regarding the future of Massachusetts’s next solar incentive program. We look forward to watching the state continue to structure competitive market based solutions, similar to those previously utilized, to continue its position as a national leader of deploying distributed solar technologies.
TweetSRECTrade will host a webinar on Thursday, August 21st at 2 pm ET to review the Massachusetts SREC market.
The last several months in Massachusetts have been dynamic. The Massachusetts SREC-II program started on April 25, 2014. Also, sweeping legislation was proposed that would have fundamentally changed the Massachusetts solar industry.
Items to be covered in Thursday’s webinar:
Register for the webinar here.
TweetThe Massachusetts SREC-II program officially launched on Friday, April 25th. The official filing can be found here and program guidelines are here. However, the application window for the new program does not open until May 6th. Any applications submitted to SRECTrade prior to May 6th will be processed with the Massachusetts Department of Energy Resources (DOER) starting on May 6th.
Once a facility receives a Permission to Operate (PTO) from its interconnecting utility, SREC-II applications should be submitted using SRECTrade’s online application. Applicants may also apply for an Assurance of Qualification from the DOER provided that the application meets certain criteria outlined in the “How to apply in the Assurance of Qualification with SRECTrade” section below. The DOER’s official guidelines for Assurance of Qualification are here.
Key highlights of the MA SREC-II program
Click here for a PDF of slides (complete with program definitions) and here for a link to a recording of our webinar covering the launch of SREC-II. Below is the summary of the various SREC-II Market Sectors:
How to Apply for an Assurance of Qualification with SRECTrade
You may apply for an Assurance of Qualification using SRECTrade’s online application starting Tuesday, May 6th. If you would like to submit the Assurance of Qualification documentation prior to May 6th, please contact us directly.
What’s Required to Submit an Assurance of Qualification?
Assurance of Qualification applications require the same information needed for a Statement of Qualification application. Additionally, the information detailed below is also required and must be uploaded to SRECTrade’s online application form.
Please note, SREC-II Assurance of Qualifications will be filled based on date of application submission. The ISA date of execution will serve as a tie breaker for applications submitted on the same day, and if the ISA date is the same for multiple applicants, the DOER will utilize a lottery process to determine the queuing position of the Assurance of Qualification application. Additionally, the DOER has provided preliminary guidance that the first week of Assurance of Qualification submissions will be treated as if they were submitted on the same day. For example, date of submission from May 6th through May 13th, will not be used to determine receipt of Assurance of Qualification. Rather, the ISA will be the first determining factor.
Also, the DOER has been recommending that projects outside of the Managed Growth category do not need to submit an application for Assurance of Qualification. There will be plenty of room under the SREC-II cap and it is not necessary during the initial stage of the program. Lastly, smaller residential and commercial projects (i.e., 25 kW and less) will likely be provided room under a future provision as the program gets close to meeting its cap.
For applications related questions
Allyson Umberger
Director of Regulatory Affairs and General Counsel
allyson.umberger@srectrade.com
(415) 763-7790
For brokerage related questions
Alex Sheets
Director of Environmental Markets
alex.sheets@srectrade.com
(802) 989-2617
For installer related questions
Sam Rust
Director of Business Development
sam.rust@srectrade.com
(415) 729-3546
Other contacts
Steven Eisenberg
Chief Executive Officer
steven.eisenberg@srectrade.com
(415) 702-0863
Tom MacKenty
Associate, Environmental Markets
tom.mackenty@srectrade.com
(415) 409-8537
Tweet
SRECTrade hosted a webinar on Monday, 4/21/2014, outlining the MA SREC-II program. A recording of the webinar is available by clicking the image below.
A link to a PDF of the presentation can be found here. The slides contain additional market sector and other SREC-II legal definitions not included in the original webinar presentation.
TweetOn March 17th, 2014, Stakeholders in the Massachusetts DOER’s Solar Carve-Out received an email with two key announcements regarding the proposed revisions to the RPS Class-I Regulation.
1) That last week, the Joint Committee on Telecommunications, Utilities, and Energy submitted their comments to the DOER on the proposed revisions. These comments were broken up into nine items, which are summarized below.
2) That the draft of the Solar Carve-Out II Program’s Assurance of Qualification Guideline was released for public comment and review. This is particularly relevant to systems that are qualified under the “Managed Growth” market sector. The DOER will be accepting comments on the draft Guideline through March 28, 2014. All comments should be emailed to DOER.SREC@state.ma.us and should contain the subject line “Assurance of Qualification Guideline Comments.”
Summary of the Committee’s comments:
Item 1: Price Volatility
Following the initial boom in solar development, spurred on by SRECs trading near the Alternative Compliance Price, SREC prices have dropped significantly. The Committee believes that the Managed Growth concept will be a useful “tool for reducing volatility in the market which should benefit both retail electric suppliers and solar facility owners.”
Item 2: Cost
The Committee supports the 1600 MW solar goal by 2020, but believe it is “important that the program is designed to achieve its goal at low costs” to the consumers. Gradually lowering the ACP and Clearinghouse Auction-II fixed prices reduces the risk of high cost to ratepayers funding these programs.
SREC Factor: Different factors to different market segments in order to more accurately match costs for each of these segments. “Considering the falling costs of solar,” committee members “encourage the DOER to review the SREC Factor Guideline even earlier than…March 31, 2016.”
Competition Imperative to Assure Low Costs: With its Guidelines, the DOER has left the possibility for competition open. The committee believes that “competition can be effective at lowering costs.”
Achieving Transmission and Distribution (T&D) Benefits to Maximize Cost Effectiveness: There is little incentive for solar growth at locations on the distribution grid that would provide maximum benefit to the grid, and ultimately ratepayers. The Committee Encourages the DOER to work closely with solar developers, utilizing tools such a solar maps, and to advocate for integrated distribution programs, which could lower total program costs.
Item 3: Equity Between Market Sectors
Under SREC-I, ground and roof projects were worth the same, but the latter cost significantly more per unit of capacity. SREC Factor helps correct the bias towards the larger systems.
Item 4: The Solar Carve-Out and Net Metering
The committee “hopes that…Solar Carve-Out II…[takes] into account the limitations on aggregate net metering capacity.” Additional changes may be necessary “to continue the growth of solar in Massachusetts.”
Item 5: Third-Party Ownership versus Direct Ownership
Though “Third-Party Ownership structures have provided…homeowners, businesses, municipalities and other government entities…with access to solar and lower energy costs,” the committee also recognizes the benefits of homeowners and businesses owning their systems outright. The committee strongly supports the DOER’s ACP-funded financing program to “help address barriers to direct ownership.”
Item 6: Class I RPS Eligibility for non-SREC GIS Certificates
SREC Factor ostensibly limits the demand for SRECs associated with the installed capacity target by generating a set portion of an SREC per megawatt-hour. However, the committee sees no reason why the portion of solar electricity that does not fall under Solar Carve-Out II Renewable Generation Attributes also does not fall under RPS Class I Renewable Generation Attributes.
Item 7: Restricting Market Sector C to a Single Parcel of Land
The section stating that arrays with a capacity less than 650kW are also eligible for Market Sector C does not specify that this capacity should be measured as the total capacity of Solar Carve-Out II units on a single parcel of land. The committee believes there ought to be such a provision: without one, larger projects that should be restricted to managed growth may inappropriately be able to access Sector C.
Item 8: Access to Solar for Non-Profit Institutions
Although non-profits make up 15% of the Commonwealth’s employment, “less than 3% of solar projects have been developed by or on behalf of non-profits.” The DOER should institute changes to the proposed regulations or to the SREC Factor guidelines to help remedy this discrepancy.
Item 9: Pre-2010 Solar Systems
Although early-adopters of the commonwealth rebate program may have received larger rebates than late-comers, many of these aggregators “have abandoned their solar REC aggregation” due to the scarcity of Class I REC-generating facilities in Massachusetts, and consequent difficulty of selling their attributes. The committee would like to the DOER consider offering Solar Carve-Out I or II eligibility to pre-2010 systems.
Further/In-depth reading:
The Joint Committee on Telecommunications, Utilities, and Energy’s full comments
RPS Solar Carve-Out II Assurance of Qualification Guideline
DOER Draft of SREC-II Regulations
The Renewable Energy Portfolio Standard – Class I
Tweet
On Thursday, February 13th, the DOER announced that a new draft of the Massachusetts RPS Class I Regulations 225 CMR 14.00 was formally submitted to the Joint Committee on Telecommunications, Utilities, and Energy for review. The draft contains key language for the creation of the touted SREC-II program. Please find the announcement letter from the DOER here. The filing is available here. Given this step and further formal review requirements that the revised regulations must undergo over the next few weeks, it is our understanding that the SREC-II program will likely become effective in early Q2 2014.
The DOER’s letter also clarifies that non-operational projects qualified under SREC-I may not also be qualified under SREC-II, without first withdrawing SREC-I qualification.
TweetOn Friday, January 24, the Massachusetts Department of Energy Resources (MA DOER) held a public hearing in Boston. The meeting allowed MA solar stakeholders to provide feedback and comments on the proposed SREC-II regulations. Additionally, the DOER will be accepting written comments on the SREC-II legislation. All written comments are due by this Wednesday, January 29th at 5 p.m. ET. Comments can be submitted electronically to DOER.SREC@state.ma.us or to Michael Judge, via mail to the Department of Energy Resources, 100 Cambridge Street, Suite 1020, Boston, MA 02114.
For an overview of the draft regulations, see our blog post here: DOER Releases Draft of SREC-II Regulations. As it currently stands, it appears the SREC-II program will be put in place as early as the beginning of Q2 2014. We’ll continue to provide more information on the development and implementation of the program as it becomes available.
Tweet