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
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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.
Following its review of public comments on the draft Guidelines it released in late January, the Department of Energy Resources has posted the final versions of the following SMART Program Guidelines:
- Definition of Agricultural Solar Tariff Generation Units Guideline
- Definition of Brownfield Guideline
- Land Use and Siting Guideline
- Low Income Generation Units Guideline
- Statement of Qualification Reservation Period Guideline
Additionally, DOER has posted an updated PowerPoint presentation that covers details related to program design and implementation and reflects changes and updates made since the January 31, 2017 stakeholder presentation that was previously available on the website.
Lastly, DOER has created a value of energy and incentive calculator for Behind-the-meter Solar Tariff Generation Units. This calculator is intended to be a practical tool to calculate the Value of Energy and fixed incentive compensation rate for behind-the-meter systems. The calculation is based on project type, size, distribution company service territory, customer rate class, and capacity block. This workbook does not necessarily reflect the final tariff value a system will be qualified for, but is meant to be a tool to understand and estimate the value that a particular customer may receive under different scenarios.
All of these documents can be found on DOER’s website.
DOER continues to evaluate written comments received on the draft Energy Storage Adder Guideline and the drafts of its Customer Disclosure Forms, which have also been released for public comment. DOER hopes to finalize its review of these documents and post final versions soon.
If you have any questions regarding these documents, please direct them to DOER.SMART@state.ma.us.
Effective with the Q4, 2017 minting, MassCEC made a change to the way they report SREC production to the NEPOOL GIS. MassCEC will no longer roll over month-to-month fractional MWh production. Total monthly production in MWh, rounded to the nearest whole kilowatt-hour (i.e., 1,879.36 kWh reported to PTS = 1.879 MWh reported to NEPOOL) will be reported to the NEPOOL GIS. The NEPOOL GIS will continue to apply the SREC II Factor to the generation. This new process will allow earlier SREC generation as MassCEC is eliminating one of two monthly carry-forwards. NEPOOL GIS will continue to carry-forward partial eligible SREC due to the SREC Factor. The examples below illustrate both the previous process and the new process.
For our Installer Partners:
This is a reminder that March 31, 2018, is the deadline by which SREC II facilities over 25 kW DC must be mechanically complete or have received their permission to operate in order to qualify under current SREC Factor levels. While the SREC II program will continue to qualify eligible facilities until the SMART Program is in effect later this year, facilities larger than 25 kW DC that are mechanically complete or receive their permission to operate after March 31, 2018 will receive a reduced SREC Factor as detailed below. In order to demonstrate that a facility is mechanically complete, email Amy@Knollwoodenergy.com one of the following forms of documentation as soon as possible:
1. A Certificate of Completion, signed by the local wiring inspector; or
2. Proof the wiring inspection has been scheduled; or
3. A signed affidavit by the engineer of record stating the system is mechanically complete, including the Professional Engineer seal.
The following is a summary of applicable SREC Factors for facilities larger than 25 kW DC according to a facility’s mechanical completion date:
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Important to Note: All facilities with a capacity of 25 kW DC or less will continue to be qualified with an SREC Factor of 0.8 until the SMART Program Effective Date, as defined in 225 CMR 20.00, so long as they have both received their permission to operate and we have submitted an SREC II Application.
More details on SREC Factors and deadlines can be found on the Knollwood Energy website here and here.
All questions regarding documentation showing proof of mechanical completion should be submitted to Amy@KnollwoodEnergy.com and cc: Alane@KnollwoodEnergy.com.
Massachusetts Installers: This post is to help clarify timing for the end of the SREC program. As of today, NO dates have been announced yet by DOER for the start of SMART. Please use this as a guide to understand the MassCEC deadlines over the next 6 months. Below are firm dates by which Knollwood Energy of MA must submit your customers’ SREC registrations.
October – December, 2017 Interconnections:Systems that interconnected Q4 2017, or earlier and are not registered for SRECs yet, must have the SREC application submitted to DOER on or before February 15th in order to have their 40 quarter eligibility be effective Q4, 2017.
January – March, 2018 Interconnections:
Systems that interconnect Q1 2018 or earlier and are not registered for SRECs; the 40 quarter eligibility date will be Q1 2018 as long as we submit the registration on or before May 15th.
April – June Interconnections:
Systems that interconnect in Q2 2018 or interconnected earlier and miss the May 15th deadline MUST be registered on or before August 15th. Nothing has been announced yet but it is likely that August 15th will be the FINAL registration deadline for all systems to get into the SREC program.
Systems 25kws and less will not be approved into the SREC program until they have the permission to operate.
Systems OVER 25kws that are not yet interconnected:
These systems should get approved into the SREC program as soon as they have a Certificate of Completion. We are registering these systems for SRECs with CoC paperwork. Even if the PTO is after SMART starts, they will be in the SREC program as long as we submit the registeration with the CoC.
The difference between the PTO and CoC:
PTO: utility sent email stating the system can be turned on.
CoC: system is completely installed and just waiting for Permission from the utility to turn on.
It is very important that we are notified immediately of all new customers.
If you have your customers sign our contract, email them to Cindy@Knollwoodenergy.com.
If we work directly with your customer, email the following to Karen@Knollwoodenergy.com:
Customer Name
System Address
Customer Email
Customer Phone Number
System Size
Date System Interconnected
If you have any questions please call 908-955-0590 or email Info@Knollwoodenergy.com.
The Distribution Companies (Nat’l Grid, Unitil, and Eversource) have selected CLEAResult, Inc. as the a Solar Program Administrator for SMART, and have issued an RFP for approximately 100 MW solar projects in their respective territories.
The date and time for the bidder’s conference is THIS FRIDAY, November 17 1-3pm at the below location.
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From the MA DOER: The Department of Energy Resources (DOER) takes this opportunity to share two significant announcements regarding the Solar Massachusetts Renewable Target (SMART) Program.
DOER is pleased to announce that Eversource, National Grid, and Unitil (collectively, the Distribution Companies), have selected CLEAResult, Inc. as the Solar Program Administrator. CLEAResult will be responsible for developing a program website, application portal, administering the initial 100 MW procurement, and performing the review of all applications submitted under the program. CLEAResult will be partnering with Clean Power Research to develop the application portal for the SMART Program. DOER and the Distribution Companies look forward to working with the CLEAResult team as we continue to prepare for the launch of SMART.
Additionally, as part of the SMART Program and pursuant to 225 CMR 20.07(3)(a), the Distribution Companies, in consultation with DOER, have developed a request for proposals (RFP) for approximately 100 MW solar projects in their respective utility service territories. This RFP was jointly issued by the Distribution Companies earlier today and aims to procure approximately 100 MW of eligible solar projects statewide. The RFP is posted on both the SMART Program website and DOER’s website.
Bidders will be able to submit an application with respect to the RFP through CLEAResult’s application website, masmartsolar.powerclerk.com, which will be open for bid submissions from November 27, 2017, through the application deadline of 5:00 PM EDT on December 5, 2017. Results of the RFP will be announced by DOER no later than January 11, 2018, and will establish the Block 1 Base Compensation Rates under the SMART Program, pursuant to 225 CMR 20.07(3)(b) and (c).
As required by 225 CMR 20.07(3)(a)1., the Distribution Companies will be hosting a bidder’s conference at the following time and location:
Friday, November 17, 2017
1:00 – 3:00 PM ET
50 Washington Street, Westborough, MA 01581
Prospective bidders are also able to participate remotely via a Skype webinar at:
https://meet.lync.com/clearesult5-clearesult/sam.nutter/m4166lyw
or via telephone at:
Conference ID# 54719333
The purpose of bidder conference is to provide interested bidders with an opportunity to obtain more information on the RFP and to answer any questions regarding the RFP. Written questions on the RFP will be accepted through November 20, 2017 at 12:00 PM ET and should be submitted toma.smart@clearesult.com. Responses will be provided by November 22, 2017.
This RFP is the next step in the process towards implementation of the SMART Program. For information on the current status of the DPU proceeding on the model SMART tariff filed by the Distribution Companies, stakeholders should visit the DPU file room and search for docket number 17-140.
If you have any questions regarding the RFP, please direct them to the CLEAResult team atma.smart@clearesult.com or 888-989-7752.
Regards,
Judith Judson
Commissioner
Department of Energy Resources
1. The MassCEC Production Tracking System (PTS) tracks monthly total kWh of production data reported by the system authorized representative/reporter.
2. Once a MWh (1,000 kWh) has been generated, MassCEC reports the whole MWh to NEPOOL GIS. Any remaining kWhs are carried forward to the first month of the next quarter.
3. NEPOOL GIS applies the SREC II factor to the MWh reported, creates 1 SREC II for each eligible MWh reported, and carries forward any remaining fractional SREC II to the next generation month.
This process may require a system to report a total of two MWhs of production before the first SREC is created.
To read further about the SREC factor calculation process, click here:
SREC Factor for the SREC II program. is published by DOER and MassCEC to further explain the process.
Thanks,
Alane Lakritz
President
Knollwood Energy of MA LLC
Your best resource for selling and buying Renewable Energy Credits!
New Hampshire customers and installers, you might be interested in attending the 2017 Local Energy Solutions Conference on October 28th in Concord.
“The annual Local Energy Solutions (LES) Conference is co-hosted by NHSEA and the Local Energy Solutions Workgroup. The conference brings together:
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State and regional clean energy leaders
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Policy makers
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Industry representatives
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Municipal and school staff
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Engaged citizens
Featuring diverse exhibitors, pitch challenges, panel discussions, and a keynote address, the LES Conference attracts over 260 attendees each year for a day-long event.
The event is held at the Grappone Center in Concord, NH, a sustainable conference center powered by solar energy. The conference features fresh, local cuisine and prizes valued at over $1,000.”
More info at https://www.nhsea.org/local-energy-solutions-conference
The NH Public Utilities Commission (PUC) released the new budgets for Fiscal Year 2018 (July 1, 2017- June 30, 2018). The budgets are very low for the solar rebate programs, and likely will not be able to meet the historical annual demand for rebates at the current rebate levels.
In summary:
- The Residential Solar Rebate Program Budget is $844,000
- The C&I solar rebate program budget Category I is $468,300
- The C&I solar rebate program budget Category II is $453,000
- The RFP for Grants budget is $800,000
These above new funding allocations must also serve the wait-listed projects, which total about $600,000 for the residential program alone, leaving just ~250,000 for new, future applications.
The PUC is not re-opening any of the closed rebate programs to new applications at this time.
The PUC will hold a public comment hearing on Tuesday October 10 at 2:00 to consider modifications to the Residential Solar Rebate Program. Written comments will also be accepted through October 20th, if you cannot make the hearing.
Before the hearing on the 10th, PUC Staff will also release their recommended program changes.
NHSEA will be making comments, and we encourage members to attend the hearing or provide comments to the Commission and/or to communicate with us as well so that we can advocate for the next best steps for the industry and customers in this challenging situation.
-Kate Epsen, Executive Director, NH Clean Tech Council, NHSEA
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