Following this Knollwood Energy announcement, please read update from the Massachusetts Clean Energy Center.

From Knollwood Energy: We would like MA residents to know that Knollwood Energy of MA is an active aggregator in the APS Renewable Thermal Program.  We will monetize the Alternative Energy Credits (AECs) that your system will generate.  Knollwood Energy of MA manages eligible systems of all sizes from the smallest systems that are eligible for minting a onetime lump sum incentive, and intermediate and large systems who receive an ongoing quarterly incentive.
Eligible Technologies: Solar Thermal Heat Pump, Woody Biomass, Automatically fed biomass boilers and furnaces, Wood pellets, chips, Blended or pure biogas (methane) and biofuels (liquids), Compost Heat Recovery.

Knollwood Energy is a family run business and one of the largest aggregators in the country. We have been monetizing credits since 2006.  Client satisfaction is our primary focus. Knollwood Energy provides all of our customers with the same high level of service which has earned us multiple referrals and high customer retention. Our experience, size and direct relationship with the buyers enables us to maximize the revenue for all of our customers.  We transform the individual system into a large institutional seller by combining our customer’s credits.  We buy credits from residential and commercial systems, bundle them and sell them in bulk direct to the utilities that need to satisfy compliance requirements.  The utilities pay us a premium to get a large quantity of credits in one transaction. We only represent our customers/the sellers and we get paid to maximize the best price for you.

Finally, we only represent our customers/the sellers.  We get paid to maximize the price we get. Knollwood Energy of MA will be managing eligible systems of all sizes from the small systems that are eligible for Upfront Minting of the AECs, and intermediate and large systems.
Contact us immediately if you have a system that qualifies for the APS Renewable Thermal Generation Unit, with a the Commercial Operation Date on or after January 1, 2015, and for a Fuel Cell Generation Unit, the Commercial Operation Date on or after January 1, 2017.  We are actively registering systems now!

From the Massachusetts Clean Energy Center (CEC):
Dear Clean Heating & Cooling Stakeholder,

Since 2015, MassCEC has committed $48 million through its Clean Heating & Cooling (CH&C) Programs to support the development of the high-efficiency air-source heat pump (ASHP), ground-source heat pump (GSHP), and modern wood heating (MWH) industries. Over the last four plus years, we’ve seen enormous growth in these markets and, with that, stronger than anticipated program participation and budget expenditures.

Because of these funding limitations, MassCEC is ending its Commercial GSHP and Commercial MWH Programs effective immediately and committing $1.35 million to the Residential GSHP and Residential MWH Programs. We believe that these significant program changes will extend the duration of the Residential GSHP and Residential MWH Programs through early 2020. MassCEC’s Whole-Home ASHP Pilot will retain its funding amount of $500,000. Our Solar Hot Water Program, which is funded separately, will not be changed.

In order to increase transparency about available funding going forward, MassCEC will be posting remaining program funding amounts on our website. MassCEC will post these caps on our Air-Source Heat Pump Installer Resources page, Ground-Source Heat Pump Installer Resources page, and Modern Wood Heating Installer Resources page. While some of MassCEC’s programs are ending, incentives are available through Mass Save and/or the Massachusetts Alternative Energy Portfolio Standard (APS). Please see the table below for a summary of program changes and alternative incentives.

Detailed Description of Program Transitions

In March 2019, MassCEC ended its Residential Air-Source Heat Pump Program and replaced it with a Whole-Home ASHP Pilot Program with a $500,000 budget which is available until the end of 2019.  MassCEC closed its Commercial Variable Refrigerant Flow Program at the end of June.

For our Residential GSHP and MWH Programs, MassCEC has allocated a joint budget amount of approximately $1,350,000. These programs will continue to run until all funding is awarded. Once funding is claimed, MassCEC will close these programs to new applications.

MassCEC closed our Commercial-Scale and Small-Scale Commercial GSHP and MWH programs on July 11. Any applications previously received will be processed and any awarded projects will retain their awards.

Even as our financial incentives wind down, MassCEC intends to stay active in promoting clean heating and cooling technologies, which are a crucial piece of the state’s efforts to meet our Global Warming Solutions Act targets. MassCEC will continue to run community-based education campaigns like HeatSmart, we intend to increase our statewide outreach and education efforts, and our workforce team is supporting internships for vocational high school students at clean energy companies, including clean heating and cooling companies.

If there are other efforts you would like to see us work on or if you have any questions, please contact us at ASHP@masscec.comGSHP@masscec.com,BiomassThermal@masscec.com, or (617) 315-9300. 

Thank you for your understanding during this significant transition in MassCEC’s programs.

Sincerely,

The MassCEC Clean Heating & Cooling Team 
Massachusetts Clean Energy Center
63 Franklin St, 3rd Floor, Boston, MA 02110
ASHP@masscec.com
GSHP@masscec.com
BiomassThermal@masscec.com
(617) 315-9300

The legislature passed and the Governor signed legislation yesterday that effectively removes the solar carve out from the states renewable energy goals.  Additionally, it reduces future renewable requirements.  The impact of this law will be to significantly reduce the price and demand for SRECs.  We are currently expecting to see prices in the $4 range.

Clean Energy New Hampshire (CENH) provides the following update on energy bills in the NH Legislature:

As of July 22
“Governor Sununu has acted on three bills related to clean energy:

SB168 was vetoed. This bill would have increased the requirement for solar energy under the Renewable Portfolio Standards (RPS) incrementally each year until 2025. The current goals listed under the RPS are very small compared to our neighboring states. This bill was significant to help stabilize the market for Renewable Energy Credits and continue to promote the development of solar. Clean Energy NH supported this bill; the Governor’s veto is a negative result.

SB165 was signed. This bill, also known as the “Low-Income Community Solar Act of 2019”, enables on-bill crediting for group net metering customers, establishes an adder for qualifying low-income community solar projects, and requires the Public Utilities Commission to authorize two new low-moderate income community solar projects in each utility service territory beginning in 2020. CENH supported this bill and the Governor’s signature is a good result

SB205 was vetoed. This bill would have extended the ability for the Public Utilities Commission to approve raising the System Benefits Charge for the Energy Efficiency Resource Standard (EERS) with approval of the general court fiscal committee but without the approval of the full general court. This is important for the next iteration of the EERS to move forward in a timely manner. The bill also made some minor modifications to the charges of Energy Efficiency & Sustainable Energy (EESE) Board, which would have enabled the Board to serve as a stakeholder forum that makes recommendations to efficiency program administrators. CENH supported this bill and the Governor’s signature is a negative result.”

As of July 19

Vetoed: HB365 (to raise the net metering ca), SB72 (to eliminate REC sweeping), SB307 (to enable towns to invest in more advanced outdoor lighting), SB275 (to make all state vehicles zero-emission by 2039)

Signed: HB156 (study commission on a state energy dept.), SB24 (re-authorizing RGGI), HB562 (updating building codes)

Bills Awaiting Action:SB168 (to increase solar under the RPS), SB165(promoting low-income community solar),SB286 (relative to municipal aggregation), HB582 (directing RGGI rebates to efficiency), SB167 (clean energy resource rocurement commission)

To track progress of these and other energy bills in New Hampshire, visit CENH’s website at https://www.cleanenergynh.org/energy-bills

June 26, 2019

Governor Sununu vetoed a bill that would have supported Renewable Energy Credits in New Hampshire.
SB72 was intended to correct “Renewable Energy Credit (REC) sweeping”, by which the utilities can count any unregistered RECs against their compliance obligations under the Renewable Portfolio Standards. This has led to a distorted REC market with very low REC prices, negatively impacting system owners and project economics. SB72 would have removed the ability for utilities to count unclaimed RECs and restore the market to its intended form and function.
We had hoped the passing of this bill would have stimulated the REC price.  Without it, we will continue to see very depressed prices.

If you are not a customer of Knollwood Energy of MA and you have unsold SRECs, please contact us immediately!

Alane Lakritz, Managing Partner,Knollwood Renewables Inc.862-432-0259

Message from MA DOER:

Dear Solar Carve-out Stakeholder,

DOER takes this opportunity to remind stakeholders that the Solar Credit Clearinghouse Auction Accounts for both the Solar Carve-Out and Solar Carve-Out II are currently open for deposits. Deposits will continue to be accepted through the end of June 15th. If vintage 2018 SRECs are not sold or deposited into the auction as of that date, it is very unlikely that SREC owners will be able to obtain any value from them. Given current market conditions and anticipated market undersupply in both markets, DOER does not anticipate that there will be a need for deposits into either auction account (i.e. SREC I and SREC II auction account) this year. To the extent that SREC and SREC II owners are considering depositing SRECs into the auction account, DOER strongly encourages them to try to sell their SRECs into the market before the close of the fourth quarter trading period on June 15th. Given current market pricing, SRECs and SREC IIs sold outside of the auction will likely be substantially more valuable to owners and will avoid unnecessary Alternative Compliance Payments being made by Retail Electricity Suppliers. DOER has a non-comprehensive list of SREC brokers that can be contacted to help sell SREC I and SREC II certificates outside of the Auction. That list can be found here. Instructions on how to deposit SRECs into one of the auction accounts can be found here. Finally, DOER uses this opportunity to inform all RPS and Solar Carve-out Stakeholders that it has obtained a preliminary 2018 retail load obligation figure, upon which compliance obligations for 2018 will be based. For compliance year 2018, total retail sales in Massachusetts were equal to approximately 46,448,304 MWh. This number is posted here. If you have any questions, please direct them to DOER.SREC@state.ma.us.

This is a reminder that November 26, 2018, has been established by DOER as the transition date from the SREC II Program to the SMART Program

SMART Application Portal and Queue

As of 12:00 PM ET on November 26, 2018, the SMART Statement of Qualification application portal managed by CLEAResult, the Solar Program Administrator, will open to begin accepting Statement of Qualification Applications for prospective Solar Tariff Generation Units (“STGU”) seeking to qualify under SMART. This will mark the start of the Initial Application Period, as described Section 3(a) of DOER’s Statement of Qualification Reservation Period Guideline.  

The initial application period will last until 11:59 PM ET on November 30, 2018. All applications received between 12:00 PM ET November 26, 2018 and 11:59 PM ET November 30, 2018 will be considered to have been received at the same time for the purposes of establishing a queue to process applications for placement into Capacity Blocks. All applications received on or after 12:00 AM ET December 1, 2018 will be reviewed on a first come, first served, basis.

Links to the individual electric distribution company application portals can be found below:

SMART Webinar

On October 24, 2018, CLEAResult, DOER, and the electric distribution companies hosted a webinar that provided a demonstration of the application portal and a walkthrough of the steps involved in submitting an application. This webinar is available at www.masmartsolar.comSREC II Transition Process

Facilities that intend to qualify under SREC II must meet the following deadlines and requirements:

Facilities 25 kW DC and Less 

A facility sized 25 kW DC or less must have received its permission to operate or authorization to interconnect on or before November 26, 2018 in order to qualify for SREC II. Applicants will have until February 15, 2019 to submit an SREC II application for facilities that meet this and all other program eligibility criteria.

Facilities Larger than 25 kW DC

A facility larger than 25 kW DC must demonstrate that it was mechanically complete on or before November 26, 2018 in order to qualify for SREC II. Documentation that a facility was mechanically complete by this date must be submitted to DOER by no later than December 10, 2018, and may include one of the following:

1. A completed Certificate of Completion signed by the local wiring inspector;

2. Documentation that a wiring inspection has been scheduled for a date shortly after November 26, 2018;

3. A signed affidavit from the engineer of record that the facility is mechanically complete and is only awaiting the authorization to interconnect from the local utility company; or

4. Other documentation satisfactory to DOER.

Tariff Information

Pursuant to 225 CMR 20.05 (2), a STGU that receives a Statement of Qualification under the SMART Program will be eligible to receive payments upon the effective date of the SMART Tariffs as approved by the DPU.  In the 17-140-A Order (“17-140-A”), the DPU established the process by which the Electric Distribution Companies (“Distribution Companies” or “Company” individually) will finalize Company-specific SMART Tariffs. While DPU approval of the company-specific SMART Provisions has not yet occurred, Statement of Qualification Applications for facilities seeking eligibility under SMART may still be submitted for review and approval by the Solar Program Administrator and DOER, as described above.

All stakeholder questions on the transition process or the SMART application process should be directed to DOER.SMART@mass.gov or MA.SMART@clearesult.com.  All questions related to SREC II eligibility should be directed to DOER.SREC@mass.gov.

From the MA DOER:

“This serves as notice that pursuant to its authority under 225 CMR 14.00 and 225 CMR 20.00, DOER has coordinated with the electric distribution companies to establish November 26, 2018 as the transition date from the SREC II Program to the SMART Program.

This date has been selected to ensure that the distribution companies have sufficient time to comply with all requirements of the Department of Public Utilities DPU-17-140-A order on the model SMART tariff and to ensure an orderly transition between the programs. Specifically, this will give the distribution companies the necessary time to be ready to expeditiously install production meters following the transition date so that they may begin issuing payments to the first customers to enroll under the SMART tariffs.

SMART Application Portal and Queue

As of 12:00 PM ET on November 26, 2018, the SMART Statement of Qualification application portal managed by CLEAResult, the Solar Program Administrator, will open to begin accepting Statement of Qualification Applications for prospective Solar Tariff Generation Units (“STGU”) seeking to qualify under SMART. This will mark the start of the Initial Application Period, as described Section 3(a) of DOER’s Statement of Qualification Reservation Period Guideline.

The initial application period will last until 11:59 PM ET on November 30, 2018. All applications received between 12:00 PM ET November 26, 2018 and 11:59 PM ET November 30, 2018 will be considered to have been received at the same time for the purposes of establishing a queue to process applications for placement into Capacity Blocks. All applications received on or after 12:00 AM ET December 1, 2018 will be reviewed on a first come, first served, basis.

SMART Webinar

On October 24, 2018, CLEAResult, DOER, and the electric distribution companies will host a webinar from 3:00 PM ET – 5:00 PM ET that will provide a demonstration of the application portal and a walkthrough of the steps involved in submitting an application. This webinar will be recorded and posted to www.masmartsolar.comClick here to register for the webinar and participate in real-time.

SREC II Transition Process

Facilities that intend to qualify under SREC II must meet the following deadlines and requirements:

Facilities 25 kW DC and Less

A facility sized 25 kW DC or less must have received its permission to operate or authorization to interconnect on or before November 26, 2018 in order to qualify for SREC II. Applicants will have until February 15, 2019 to submit an SREC II application for facilities that meet this and all other program eligibility criteria.

Facilities Larger than 25 kW DC

A facility larger than 25 kW DC must demonstrate that it was mechanically complete on or before November 26, 2018 in order to qualify for SREC II. Documentation that a facility was mechanically complete by this date must be submitted to DOER by no later than December 10, 2018, and may include one of the following:

1. A completed Certificate of Completion signed by the local wiring inspector;

2. Documentation that a wiring inspection has been scheduled for a date shortly after November 26, 2018;

3. A signed affidavit from the engineer of record that the facility is mechanically complete and is only awaiting the authorization to interconnect from the local utility company; or

4. Other documentation satisfactory to DOER.

Tariff Information

Pursuant to 225 CMR 20.05 (2), a STGU that receives a Statement of Qualification under the SMART Program will be eligible to receive payments upon the effective date of the SMART Tariffs as approved by the DPU.  In the 17-140-A Order (“17-140-A”), the DPU established the process by which the Electric Distribution Companies (“Distribution Companies” or “Company” individually) will finalize Company-specific SMART Tariffs. The Distribution Companies will be filing a joint model “SMART Provision”, which is the SMART tariff, not later than October 15, 2018.  Following DPU review, the DPU will render its decision on the model SMART Provision and direct each Company to file company-specific SMART Provisions, which are further subject to review and approval by the DPU.  Consistent with 17-140-A, the Distribution Companies will not begin to issue incentive payments or apply Alternative On Bill Credits until the DPU approves company-specific SMART Provisions. However, if the DPU approval of the company-specific SMART Provisions has not yet occurred prior to November 26, 2018, Statement of Qualification Applications for facilities seeking eligibility under SMART may still be submitted for review and approval by the Solar Program Administrator and DOER, as described above.

All stakeholder questions on the transition process or the SMART application process should be directed to DOER.SMART@mass.gov or MA.SMART@clearesult.com.  All questions related to SREC II eligibility should be directed to DOER.SREC@mass.gov.”

From the MA DOER:

“On September 26th, the Department of Public Utilities (DPU) issued an order approving the model SMART tariff that was jointly filed by the electric distribution companies, an action that triggers the start of the transition process from the SREC II Program to the SMART Program.

The DPU’s order gives authorization to begin accepting applications for facilities seeking to qualify under the SMART Program. DOER is actively coordinating with the electric distribution companies and SMART Solar Program Administrator, and will soon announce a specific date when the application platform will be available.

To provide more detailed information on SMART Program requirements and the transition process between SREC II and the SMART Program, DOER will be holding a series of stakeholder meetings on the following dates and at the following locations:

DOER will provide further guidance on the SMART Program effective date, the expected effective date of each Distribution Company’s tariffs, and the transition between SREC II and the SMART Program as it becomes available.

In the meantime, SREC II remains in effect and DOER will continue to accept applications.

All stakeholder questions on the transition process should be directed to  DOER.SMART@mass.gov.”

Comments to the PUC by Knollwood Energy on New Hampshire’s Renewable Portfolio Standard law:

Dear Ms Cramton,

Knollwood Energy is one of the largest managers of NH Class 2 RECs in the state of New Hampshire. Our customers are homeowners, small businesses and large businesses that have made the financial investment to install solar on their homes and businesses. A part of their investment decision was an assumption of a properly functioning RPS. However, due to the “Free RECs” language in the RPS, actual demand for NH Class 2’s has been negligible versus the assumed demand based on the percent requirement listed in the RPS. What we call “Free RECs” is the net metering credit language which reduces the demand based on the amount of solar that is installed but not registered. On our customers behalf, we appreciate the opportunity to comment on RSA 362-F.

The state of New Hampshire has a Renewable Portfolio Standard (RPS), whose goal is to provide incentives to increase the amount of renewable energy installed within the state. A cursory analysis of the demand from the RPS is pretty standard. In New Hampshire it increases from .3% to .7% from 2017 to 2020. This would create a clear requirement in all states, except for New Hampshire. New Hampshire provides a net metering credit to electricity providers for solar facilities that are interconnected, but not producing RECs. The net metering credit reduces the demand for Class 2 RECs and is calculated annually by the New Hampshire Public Utility Commission (PUC).

The impact of this RPS reduction is clearly stated on the PUC’s RPS Compliance website, “For calendar year 2017, the Class II Net Metering Credit exceeds the RPS Class II compliance obligation of 0.3%.” In other words, the demand was reduced to 0! In 2016, the net metering credit reduced the demand from approximately 32,147 RECs to 5,529. The impact of this has been a drastic reduction in prices received by New Hampshire solar owners, with pricing today approximately $5, as the market waits to see what the net metering credit is for 2018.

There are at least two major issues with the current legislation that SB 447 is looking to correct.

1) The whole concept of the net metering credit. The idea that systems that do not generate RECs, punishes all of the ones that do, does not make sense and is not standard in RPS’s in other states. Again, in 2017, this reduced demand to 0. That can not possibly be the intent of the RPS.

2). Another issue with the RPS is calculating how much net metering credit each non-issuing system qualifies for. The capacity factor estimates the amount of output that is expected from a particular technology. The higher the capacity factor, the larger the expected output and in this case the bigger the credit given to the electricity suppliers. New Hampshire currently uses a capacity factor of 20%. This number is too high and is not supported by any empirical data. The capacity factor is impacted by the quality of installation, the climate and the amount of sun in the particular area of the country. Massachusetts, which is very similar to New Hampshire in the main drivers of solar capacity factor, has calculated an 8 year average of their solar systems of 13.35% using actual data. Why is this important? The net metering credit gives credit based off assumed output, which is calculated from the capacity factor. Using a 20% capacity factor, a 10kw solar system (average home size), would give the electricity suppliers a credit of about 17,520 kwh/year. Using the more accurate 13.35% capacity factor would drop that credit to 11,685 kwh/year. The more accurate capacity factor will reduce the net metering credit and increase the demand to more appropriately reflect reality. The PUC should recommend either using the empirically supported 13.35% number or commit to doing it’s own analysis of New Hampshire based facilities.

We strongly support a robust solar market in New Hampshire and hope that some of our comments will be implemented. The most important would be the complete elimination of the net metering credit. At a minimum, the capacity factor should be calculated off of read data and adjusted as soon as possible.

Thank you,

Alane Lakitz

Managing Partner Knollwood Renewables Inc.

Knollwood Energy of MA LLC

*******************************************

New Hampshire’s Renewable Portfolio Standard (RPS) law requires the Public Utilities Commission to conduct a review of the RPS program and to make a report of its findings to the General Court by November 1, 2018. In addition to literature review, research, and data analysis, the PUC is seeking stakeholder input. Please focus comments on the statutory study requirements defined in RSA 362-F:5. Written comments will be accepted through Friday, September 7, 2018. Please submit written comments electronically to: karen.cramton@puc.nh.gov. Please also send one original copy to: Karen Cramton, Sustainable Energy Division Director New Hampshire Public Utilities Commission, 21 S. Fruit Street, Suite 10, Concord, NH 03301-2429.

 

 

Solar Carve-out II Renewable Generation Units with an RPS Effective Date on or before March 31, 2018 will be eligible to receive Solar Carve-out II Renewable Generation Attributes for forty quarters.  However, no Solar Carve-out II Renewable Generation Unit will generate SRECs after Compliance Year 2027.  As a result of this, all Generation Units that become operational after January 1, 2018 will receive fewer than forty full quarters of SRECs.

All systems that have production to report for Quarter 1 of 2018 must have their SREC application submitted by the May 15, 2018 deadline.  Email the customer information to Cindy@KnollwoodEnergy.com as soon as possible.

If you have any questions, do not hesitate to email or call.