Solar Renewable Energy Credits

 In January 2005, the District of Columbia (D.C.) Council enacted a Renewable Portfolio Standard (RPS) with a solar carve-out that applies to all retail electricity sales in the District. In October 2008 the RPS was amended by the Clean and Affordable Energy Act (CAEA) of 2008. Significantly, this legislation increased the percentage and number of benchmarks that utilities must meet, included solar water heating as an eligible technology, increased the alternative compliance payment and amended reporting requirements. The solar requirements began in 2007 at 0.005% of retail electricity sales and increase annually towards an ultimate target of 2.50% solar by 2023. Notably, both solar-electric and solar thermal resources are eligible for the solar carve-out.

Under D.C. law, a solar renewable energy credit (SREC), is equivalent to one megawatt-hour (MWh) of electricity derived from an eligible solar resource. Electricity suppliers must purchase SRECs in order to meet their compliance obligations under the law, or pay a Solar Alternative Compliance Payment (SACP) for any shortfalls in SREC purchases. The SACP operates as a ceiling on the price that a supplier would pay for SRECs used for compliance with the D.C. RPS. The SACP is set at a flat rate of $500 per MWh. The value of an SREC varies based on market conditions, but as of March 2015 sales of D.C.-sourced SRECs tracked on Flett Exchange averaged $480 per MWh. Individual trades have taken place at both lower and higher prices and it should be noted that these prices reflect SRECs generated in D.C. which may have been sold into other state SREC markets.

Under this system SRECs represent a potentially significant source of revenue for owners of qualifying solar facilities with a value determined by demand in the trading market. In D.C., net metering customers retain ownership of SRECs (or RECs) unless they agree to transfer them. A generator remains eligible to generate SRECs for as long as the facility remains certified as an eligible generator. SRECs have a three-year lifetime from the date they are created. In other words, an SREC may generally be used (i.e., retired) for compliance by an obligated electricity supplier for up to three years after the date it is created. An obligated entity may use an SREC to comply with the solar carve-out of the RPS or with the general renewables requirement. As of September 2014, total of 1,174 solar PV, 74 solar thermal system inside D.C. and 2,239 solar energy systems outside of D.C. were eligible to meet the city’s RPS requirement. In order to begin producing D.C.-eligible SRECs, generators must be certified by the D.C. Public Service Commission (PSC) as an eligible generator. In order to qualify as an eligible generator, solar facilities must be located within the District of Columbia or in locations served by a distribution feeder serving the District of Columbia.

SRECs generated by solar energy facilities that were certified by the PSC prior to February 1, 2011, are excluded from this requirement and are allowed to be used to meet the RPS solar requirement.*

When the generator has been issued a certification number, they may create an account with the PJM GATS. The PJM GATS is used to track the generation and transfer of SRECs from an eligible facility. SRECs are created in the GATS based on energy production meter readings uploaded to the system by the generator. Solar PV facilities of 10 kilowatts (kW) or less and solar thermal facilities which produce or displace less than 10,000 kilowatt-hours (kWh) per year are permitted to use an engineering estimate to generate SRECs rather metered generation data. SRECs are awarded to Solar Thermal based on their kWh savings at the ratio 3,412 BTUs = 1kWh. Solar thermal systems or collectors must be certified by the SRCC in order to qualify for the standard.**

 Background

Amendments made in 2010 by D.C. Law 18-0223 have clarified the eligibility of solar thermal facilities located within the District, and geographic eligibility of renewable (including solar) resources in general. Further amendments were made by D.C. Law 18-0303 in March 2011 to clarify the certification requirements for non-residential solar thermal systems. In August of 2011, the RPS was further amended by both the Emergency Distributed Generation Amendment Act of 2011 (B19-0384), and the Distributed Generation Amendment Act (B19-10), which increased the solar carve out from 0.4% to 2.50% by 2023. Following a Congressional Review Period, The Distributed Generation Amendment Act became D.C. Law 19-36 on October 20, 2011. The changes resulting from before mentioned legislation are reflected in the D.C. Code § 34-1432.

* Prior to D.C. Law 19-36, eligible generator solar facilities were allowed to be located within the PJM Interconnection region or a state adjacent to the PJM Interconnections region. This portion of the law was amended by D.C. Law 18-0223 in July 2010 to remove confusing language pertaining to RECs associated with electricity delivered into the PJM Interconnection region from an adjacent control area. These terms are defined in greater detail in the rules adopted by the PSC.

** This portion of the law was amended on a by D.C. Law 18-0303 in March 2011 to revise language associated with certification requirements for non-residential solar thermal systems. The prior wording of the law required all non-residential solar thermal systems to be SRCC certified without making a distinction between the collectors (i.e., SRCC OG-100) and the system (i.e., SRCC OG-300). The revised language makes this distinction, clearing the way for non-residential systems to be certified as eligible for the standard.