Renewable Energy Certificates (RECs) and Solar Renewable Energy Certificates (SRECs I and SRECs II) Revised- July 30, 2015 Preface

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1 Massachusetts Renewable Energy Certificates (RECs) and Solar Renewable Energy Certificates (SRECs I and SRECs II) Revised- July 30, 2015 Preface This is our tenth version of this report since There is at present an improving market for Massachusetts SRECs I, a depressed market continues for RECs and a relatively stable market for SRECs II has developed. Formerly all Commonwealth Solar eligible installers were required to inform customers and prospects of the Massachusetts RECS/SRECS incentives. The Commonwealth Solar rebate program has ended and SRECs II is the only production incentive for new solar Photovoltaic (PV) generation units. We ll continue to provide a thorough disclosure here and in our solar development quotes and contracts. This report is one of the most popular sections of our website. Thank you for your comments and passing it on to your colleagues and friends interested in the PV production incentives in Massachusetts. We ll start out with a summary update for our frequent website guests but there is new information in several sections. For those un-familiar with the complexities of SRECS and RECS, start with Basic Facts on page 4, and follow the end notes for important details. Just want to know how to sell them go to page 7. Summary SREC Market Prices the last week of July SRECS I were bid at just over $400. each on the open market thus small PV owners could see as much as $375. each from aggregators. The DOER 2015 Clearinghouse auction cleared on its first round with institutional buyers sweeping up SRECs at $300. each in the almost certain expectation they will have increased value when sold in 2016 and The now closed SREC 1 market will remain slightly under supplied. Readers of this report will note we were wrong in predicting that the July 2014 Clearinghouse Auction would fail. It actually went to the third and final round before clearing, an indication that non utility buyers feel upbeat that SREC 1 prices in the next few years will exceed the $ Clearinghouse price bench mark. The almost guaranteed high value for SRECs 1 in coming years is one reason the utilities in Ma are fighting solar on every front they can. Keep in mind if they did not have SRECs to buy then they would pay much higher costs ( shouldered by all ratepayers) to meet the Renewable Energy Portfolio Standard mandated in 1997 and updated in 2010 to provide higher value to Solar RECs. SRECs II from 2014 solar production have sold on the open market for around $350. thus earning small residential customers values in the range of $ for each SREC. SRECs II from 1 Q 2015 are now selling for around $315. earning residential owners in the $275. range. They will have these same or improved values these next few years. In all likelihood new PV systems coming on line since July 2014 and ongoing with the SRECS II vintage will enjoy stable pricing throughout their term. Keep in mind utilities and others in Ma are trying to end the SRECs II program with new legislation but will likely not be able to un-grandfather systems already in. For pre PV owners of small systems under 10 kw, you re only eligible to sell production attributes as RECS and these will still sell at $20.-$40. each over the next two years. Small system PV owners of RECS will find few brokers interested because of transaction costs. We at BPVS regret having to keep repeating this same message to early adopters of PV. In every policy discussion on Solar and net metering 1

2 this year and in years past we have asked that SREC status be granted to eligible early PV owners and have repeated to colleagues, legislators and officials in Massachusetts what a rude injustice this is to the pioneers who built the first eighteen Megawatts of capacity in the state. RECENT HISTORY AND PROGRAM DESIGNS SRECs II. The rapid build out of Solar PV capacity in state since 2010 had exhausted the original SRECs 1 carve out of 400 Megawatts (MW) within the Renewable Portfolio Standard(RPS) so an emergency amendment to the RPS regulation was made in the fall of 2013 to provide a transition cushion. With the cushion, the original carve out expanded to nearly 650 MW. The establishment of SRECs II through another amendment of the RPS regulation was made in May This additional carve out will amount to an unknown total of PV capacity eligible for the ten year program. DOER predicts this will allow MW of new capacity to come on line each year for the next two years. Through a last minute legislative effort in June and July the utilities and some large scale solar developers sought to overhaul the net metering and incentive policy in Massachusetts and effectively end the SRECS II program by March This legislation was defeated however the effort to reduce the SREC II incentive program duration is ongoing and bound to create changes sometime in the next several years. This table shows the SRECS II incentive value schedule now in regulation 225 CMR 14 6 Reducing Incentive Value Over Time Year Auction Price Bid $/MWh Auction Price After 5% Fee ACP Rate Values announced by DOER each year to maintain 10-year forward schedule. Creating A Cleaner Energy Future For the Commonwealth Auction Price and ACP Rate Schedules No change from prior Stakeholder Meetings Values are included in regulation The SRECS II Auction values are the same as for SRECS I for the next three years then steadily decline. The program has a ten year forward schedule so say your PV system comes on line in 2016 your last SREC II eligible year will be The ACP ( Alternative Compliance Payment ) rate is much lower than for 2

3 SRECS I ( see the next chart). The ACP rate is the price an electricity supplier or utility must pay if it cannot meet its RPS obligation with SRECs II purchased from PV systems. Ideally the market price for an SREC II will be less than the ACP rate and more than the auction rate. For small capacity PV customers it is unnecessary to explain more than to say the politics of the SREC II factors limit the value of each SREC II generated by large capacity installations. The SREC II program aimed to reduce the proportion of large over small installations. The SREC II factors and another feature of the SREC II program called the Solar Carve Out II Managed Growth Sector limit access to an excessive share of incentives for large solar developments. This limiting policy contributed to the contentious last minute legislation wherein large solar developers and the utilities contrived to overhaul solar programs in June and July 2014 and it is an indirect cause to the Net Metering Cap crisis now in the summer of SRECs I Forward Solar Carve-Out ACP Rate Schedule from regulation 225 CMR Compliance Year ACP Rate per MWh 2013 $ $ $ $ $ $ $ $ $ $ $ and after added no later than January 31, 2015 (and annually thereafter) following stakeholder review Note again that the auction bid rate for SRECs I is $ each through 2023 and ideally the market rate for SRECs I should be above that but below the ACP rate set by the regulation. In reality the market rates for SRECS I have tended below the auction rate in 2012 and This is predicted to change as supply balances demand in so SRECS I holders are expecting their value to be ~ $400. each in the year 2017 when their ACP rate is $ each. Compare the auction/ ACP split for the year 2017 for SRECS II : $ each is the auction bid rate but the ACP rate is $ each. The solar incentive policy of DOER commencing in late 2009 with the SRECs I and SRECs II was meant to increase PV capacity in state. Thus if you did not get in on SRECs I in 2010 through 2013 you will 3

4 earn a lower production incentive from SRECs II in 2014 and 2015 but still a quite generous incentive. It s a different story for those who installed PV systems prior to PV systems installed prior to 2010 are not eligible for the SRECs I or SRECs II carve out production incentive. They are only eligible to sell their production attributes as RECs. The DOER ACP RATES are updated on their website periodically. It shows the ACP value of RECS for the year 2014 at $66.16 each, for 2015 AT $67.06 EACH considerably lower than the ACP value for SRECs I or SRECs II in 2014 and The ACP rate, remember is the high end of the range. If small producers of RECs can sell them at all, $ each is the best they ll do. Basic Facts RECs & SRECs use the same metric as electricity, a MWh (megawatt hour). 1,000 kilowatt hours ( kwhs) equals 1 MWh or slightly less than the average yearly output of a 1 kilowatt (kw) photovoltaic system in our region 1 See Endnotes. Generally, a Massachusetts SREC can only be produced by a PV system on line after Jan 1, RECS are less valuable and result from various attribute defined technologies : wind, low impact hydro, biomass and from any solar PV system installed prior to 2010 but generally no earlier than Jan.1 st Other solar devices eg. for hot water, air heating or cooking etc. are ineligible however in 2014 solar hot water systems became eligible for Alternative Energy Credits and DOER is now setting rules and values. Traded as if they were real electricity, measured as a MWh, a REC or SREC represents the associated renewable energy generation attribute separated from the energy. A Generation Attribute is defined in Massachusetts 225 CMR-14 as a non-price characteristic of the electrical energy output of a Generation Unit including, but not limited to, the Unit s fuel type, emissions, vintage, and Renewable Portfolio Standard eligibility. The C stands for Certificate once the attribute is sold although Credit is commonly used to mean the attribute or the official certificate. There is a market for these certificates of renewable generation goodness managed by the New England Power Pool Generational Information System (NE-GIS or NEPOOL -GIS). Utilities and electricity suppliers must meet a state regulated Renewable Portfolio Standard (RPS). RPS compliance allows their purchase of RECs or SRECs in lieu of real renewable electricity. While utilities are the primary buyers of RECs and SRECs, there are also voluntary purchasers who wish to lighten their carbon imprint and financiers who buy their potential future value or once in existence buy to hold them for short durations up to several years. Aggregators, SREC/REC traders, listed by the state as eligible brokers sell these certificates on behalf of PV system owners or certificate owners. The actual energy from a PV system measured on the solar kwh meter at the site has a value as net metered generation reducing your electric bill 3. This is the primary value as electricity, a different financial benefit from tradable RECs or SRECs which represents the separated clean attribute of solar. Once a PV system owner sells the RECs or SRECs, the energy from their PV system is just as dirty or unsustainable as the conventional electricity mix. This may surprise some people because it is not widely known. In 2012 the Federal Trade Commission stepped in to clarify fact and fiction in the clean energy claims made in the marketplace. See page 34 example 5 in the Federal Trade Commissions Green Guide for specifics on PV. If you sell the RECs or SRECs you can say you generate and sell clean energy not that you use it. The Vermont Law School in 2015 has begun an action against Green Mountain Power, their state s largest utility, because of claims it makes to their customers that it is supplying renewable clean energy in their mix but the law suit claims they are selling the RECs from this electricity in the Massachusetts RPS market. They can t have it both ways is the upshot of this action. Almost every marketer of solar gives the impression to consumers they can have it both ways- you can be both greedy and green. 4

5 Reasons for the SRECS Program Because Photovoltaic or solar electricity is clean, costly and new, incentives have been created for its adoption. 4 Massachusetts Rebate amounts have fallen since 2002 and stayed flat from , have been reduced further in 2014 and ended in early RECs for PV were popularized in Their value consistently diminished. A special category of Massachusetts Solar RECs, SRECs was carved out of the full RECs quota to encourage new PV capacity construction. It went into effect in January The Department of Energy Resources(DOER) developed a program which prompts a floor value for SRECs for a period that has been extended to 2024 and as SRECS II could go longer. The Massachusetts SRECs incentive along with the federal 30% tax credit for investing in PV makes for an attractive return and thus to increased solar capacity in the state. Look to the next revision of this report or go to: for the latest policy pronouncements and program updates. There are many stakeholders in this policy to promote clean energy in Massachusetts; their conflicting interests contribute to its complexity. Our views here and in comments to the DOER regulatory process which are published on their website represent the perspective of early adopters and small PV system owners SREC I and SREC II Eligibility Requirements & Market History 1. Only PV systems which come on-line after 2010 ( with exceptions 2 ) are eligible for SRECs I or II As of this writing, July, 2015, well over 870 MW of PV is planned with ~ 560 MW actually on line producing. Massachusetts is one of the globe s hottest markets for solar investors because of SRECs and has attracted hundreds of firms. Large scale solar installations have already staked out the majority of SRECs I and II available. 2. The number of SRECs utilities should purchase to comply with the Solar portion of their RPS (Renewable Portfolio Standard) is adjusted upward each year. Owners must sell SRECs within a year of their creation with one exception If the utilities do not purchase SRECs to meet their annual RPS mandate then they are subject to pay an Alternative Compliance Payment (ACP) at a higher amount and this sets a ceiling price per SREC. In 2010 that amount was $ per SREC I. DOER has scaled the 2015 price at $ for an SREC I and $ for an SREC II. In the year 2023, the ceiling price is $330. for each SREC I and for SREC II in 2023, $271. each is posited. 4. SREC regulations attempt to set a floor price through a complex clearinghouse auction. As designed this auction was to provide that SRECs would have a starting value of $ ( actually $ but there is a $15.00 auction fee) The expectation was that owners would be able to sell their SRECs for more than $ each on the spot market and DOER would not have to offer a clearing auction. 5. Prior to and in March, 2012, SRECs I sold at ~$500.- $550.on the spot market In July 2012 they sold for $271. No one deposited SRECs I in the auction clearinghouse in July of In October 2012 the average price dropped to ~$245. In June 2013 they dropped to $180. each 5

6 In July 2013 the auction failed and DOER bailed out the SRECs I market at $ each In January 2014 SRECS sold for ~$ each. As of October 2014 they sell for ~ $ each. Now in 2015 prices are rebounding above the auction floor prices Reasons for SRECS value drop: A glut of new PV capacity came on line in 2012 and More SRECS were minted 6 than the utilities needed to buy. Utilities however are allowed to buy more on the NE-GIS and bank up to 10% of their needs for a given year. The glut grew this year in 2014 but will not continue. There is a bi lateral, long term, forward market for SRECs. Into this market solar developers had pre sold MA SRECs from their projects to SREC aggregators and brokers even though their PV systems had not produced them yet. Now forward SRECs II sell, we hear, for $ These are complex deals with future SRECs II and assets functioning in loans and securities. Solar developers needing cash in a hurry also explains this short selling in potential Massachusetts SRECs I in 2013 and early A few went bankrupt. Aggregators/brokers sometimes need to sell these large blocks of SRECs quickly which can cause steep discounting. The Market Forward & SREC Price Projection Massachusetts has better safe guards than New Jersey and Pennsylvania where SREC prices crashed hurting many investors. The Clearinghouse Auction can extend the life of surplus SRECs. Regulators can alter factors that will increase SREC demand slightly and legislation can make major changes to increase demand or SREC value. Generally for MA SRECs I the small system PV owner is at the mercy of market forces dominated by large PV system owners, financiers and the broker/ aggregators. It is likely the SRECs II program will be curtailed early by legislation in 2015 or That will mean no new opportunistic entrants for SRECs and an end to the solar boom in Massachusetts. Responsible industry and govt. policy makers understand that it would be very disruptive to renege on those who are grandfathered in to the 10 year SRECs term. RECS For small and large PV system owners the RECs incentive was glowingly touted in 2003 as a long term generous production incentive. Pricing began at $50.00 per REC; RECs brokers & enthusiasts predicted they would easily reach $ per REC in a few years. It did not happen. Other interests succeeded in widening the energy technologies eligible to generate RECs. RPS compliance could be purchased from generators in other states. $30.00 per REC ( $0.03 per kwh) was the average price Small producers could not renew contracts with aggregators in 2007 and their RECS went unsold and effectively expired. It is not widely understood that the SRECs quota instituted in 2010 is a percentage of the original RECS full quota. SRECs are a carve out program; as a result the RECs program saw lessened demand. By 2012 however due to the steadily increasing percentage of RECs mandated by the MA RPS and the institution of RPS mechanisms in other states, there was an undersupply, so MA utilities made ACP payments at ~ $62.00 (per REC equivalent) in ACP payments go directly to DOER and the agency is allowed to spend that money at its own discretion. In 2013 DOER bailed out the SRECs auction with $12 million of ACP money. It had collected over $70 million. Unlike SRECs which can gain an extended life through the DOER Clearinghouse auction, RECs absolutely need to be sold within a year of being produced but it is very difficult for small PV system owners to find a broker. It is a shame DOER which had been so active to aid post 2010 PV owners gain full value for their SRECs I when that market crashed have been consistently deaf to fair play for pre 2010 PV system owners. Particularly in 2012 & 2013 DOER could ve made an effort to help small system owners sell their RECs; it did not. In the Spring of 2014, the legislature through the Joint Committee on Telecommunications Utilities and Energy strongly recommended DOER correct this injustice to PV early adopters by including them in the SRECs I or SRECs II program. The legislature was ignored. 6

7 How can I sell my SRECS or RECS? You need to sell your attributes through an aggregator /broker. It is not cost effective for small PV system owners to trade on the NEPOOL GIS. DOER has compiled a list of aggregator/brokers you can contact for detailed offers. If you cannot download the list in a readable form please call or BPVS for a copy. To enable the sale of SRECs/RECs your PV system production must be reported monthly to the Massachusetts Clean Energy Center Production Tracking System ( MassCEC-PTS). When BPVS installs your PV system we make sure it is registered on the PTS for you. We ll present options to manually report or to provide automatic reporting equipment installed with your PV system. Automatic reporting is required if your PV system is over 10 kw in capacity. With either choice, BPVS installs a revenue grade, new ( not reconditioned) solar kwh meter identical to the best meters utilities use. Manual reporters will receive a username and a password from the PTS administrator. Each month the PTS system sends you notices to enter your production tally from the solar kwh meter. You ll receive multiple notices and have a ten day window to access your PV system page on the PTS and enter the total number of solar kwhs registered on your meter. If you ignore notices or forget to make the entry you can catch up the following month. We do not advise you skip months often however because the PTS system is wary of production entries that appear high and will sometimes challenge you for an explanation. Automatic reporting equipment uses a datalogger ( Data Acquisition System or DAS) interfaced to the solar kwh meter and hooked into your computer network or to direct internet access. There are many bells and whistles with automatic reporting equipment and brands and they range in cost from a few hundred dollars to several thousand. The key part of any DAS is the PTS reporting service. Most customers choose a ten year service plan; the device manufacturer is designated as your PTS reporting representative and is obligated to update your PTS tally each month for ten years. If you re only eligible to sell RECS from your PV system there are conflicting rules from the MassCEC PTS barring manual reporting 8. If you do not have high speed internet or cell phone access at your site ( you are not alone in Western Mass) and/or if you simply prefer not to use , BPVS can still provide PTS reporting services for you. More about the PTS and its relation to SRECs or RECs may be found at : The PV system usually needs at least one month s tally before it can be registered on the PTS. If you choose to sell your RECs /SRECs to an aggregator you will give them permission to access your production tally on the PTS. A degree of fraud protection is part of the PTS software; it can identify outliers and request clarification if you report more production than is possible or likely given the weather and the tally from comparable PV systems in any given month. There is also a degree of quality control, the PTS alerts you if your PV system is producing below par. Whether you manually report your tally each month to the PTS or it is automatically reported, you too have access to the PTS production tally page on their website. Massachusetts should be proud of the PTS. The aggregator will submit to NEPOOL GIS and DOER a statement of qualification for your PV system 9. All of the technical details you and they need for this document are included in our contract and system design documentation however it s often the case that an aggregator will send you a form, then tell you to ask us to fill in the technical sections for you; we re happy to do this at any time at no charge. Sometimes our customers switch aggregators after a system has been installed. Our documentation help is still a free service. At this point and after your solar system has made at least 1000 kwh or 1 MWh you re ready to sell SRECs or RECs. The aggregator you select will have a variety of plans you can option to sell the SRECs or RECs and 7

8 how you will be paid. Unfortunately, neither the DOER nor the Massachusetts Clean Energy Center nor the Office of Consumer Affairs and Business Regulation present any detailed guidance on these important plan variables. At BPVS we know that it is a conflict of interest for us to recommend any aggregator/broker, advise you on their offers or be both an aggregator and design /installation firm. Please read on to understand our policy. BPVS POLICY & DISCLOSURES on RECSs/SRECs 1. Our contracts for PV installation, service or repair do not include a clause or clauses with conditionals or any vague language that takes ownership of SRECs, SRECs II or RECs from you, or takes implied equivalents such as Carbon Credits, Emissions Credits, Pollution Offsets, Clean Energy Attributes, attributes, credits, Environmental Financial Incentives, separated benefits, or Green Tags. 2. BPVS cannot recommend any particular firm or aggregators/broker to you. It is common practice for PV installation firms to represent aggregator/broker firms, and receive commissions from them. Neither the installer nor the aggregator/broker is required to disclose such relationships. Some PV firms are also aggregators. 10 When shopping for a PV system if the PV installation firm, coordinating service firm or leasing salesperson does not disclose your eligibility for RECs or SRECs or suggests that they will take care of that for you...be careful. We supply you with the full list of MA eligible aggregator /broker firms to select one for yourself. 3. It is not that hard to research offers yourself; the sign up process with an aggregator is easy. Typically you, our new PV customer has been referred to us by a past customer who can provide you guidance. 4. BPVS supplies new ( not reconditioned) solar kwh meters identical to the best meters utilities use; our meters are digital, that is, easy to read and supplied with tamper indicating seals, unbroken and 0 kwh registered at start. We register the solar kwh meter serial number in our files and add a tamper indicating seal to the meter base hasp. Automatic DAS equipment we supply is from a third party provider unassociated with us or an aggregator/broker. Should the DOER, or the Department of Public Utilities ever challenge the meter readings or DAS reports from your site we re happy to verify the equipment installed is revenue grade and the wiring is properly routed and connected for revenue grade integrity. 5. You do not have to sell the SRECs/RECs from your PV system. Not selling them means you have retained the clean energy benefits or generation attribute with the electricity. The BPVS website includes a table to calculate deferred emissions from your personal or on site solar energy use. Go to: Clean Energy Stats 6. Aggregator/Brokers typically charge a fee ranging from 2% to 10% of the sale price they get for your SRECs/RECs. For small PV systems the aggregator bundles their SRECs with those of others to trade in large blocks. Consult your tax advisor; generally proceeds to you from SRECs/RECs sales are considered taxable income even though the aggregator does not send you an IRS form This report includes values for SRECs and RECs based on public information at the time of the report date. BPVS provides this price information, projections and analysis in a conservative light as a service to our customers assessing risk. Some solar sales pitches present SRECs and SRECs II values at their highest possible price in their financial analyses. RECs history, SRECs recent history causes us to refrain from such charming optimism for this complex market. 8

9 SRECs/RECS Pricing Conclusion Despite the unevenness of RECs and SREC values in Massachusetts the financial benefit of owning a PV system is still compelling. Our quotes analyze this for you at uniform present worth. Policies will continue to change; if our civilization is serious then incentives for solar should improve. This is why forfeiting ownership of the green attributes or environmental financial incentives etc. or settling for a low price for the duration of a ten or more frequently 20 year contact is not prudent. Endnotes: 1. Between 11:30AM and 12:30PM, on a bright sunny day a 1 kw (kilowatt) system will generate 1,000 watthours or 1 kwh(kilowatt hour). If you leave a 100 watt light bulb on for ten hours it will use 1 kwh. The average New England home without an electric hot water heater uses 650 kwhs per month. In twelve months it will use 7,800 kwhs, or 7.8 MWhs and need a 7 kw PV system to offset its utility purchases of electricity. 2. Certain PV systems which were installed in 2008 & 2009 may be eligible if those system owners did not receive rebates or grants from the Commonwealth Solar I program or its predecessors funded by the Massachusetts Renewable Energy Trust (MRET) or received a waiver from DOER officials. Pre installed photovoltaic generation systems are not eligible for the SRECs program. All post 1997 PV systems are still eligible to produce and trade their RECs as Class I RECs. Solar PV systems installed before January,1998 are not retroactively included by RPS legislated incentives for Class I RECs even though they have been and are generating solar kwh on the grid. With DOER special permission they can qualify to sell attributes as Class II RECs. Class II RECs are even less valuable. The Classifications of RECs by vintage and technology would take another essay to discuss. The Electricity Restructuring Act of 1997 established the Renewable Portfolio Standard, (RPS) with annually increasing goals for cleaner generation on the grid from regulated utilities. Graduated in price for the cleanliness of the renewable energy source, utilities and suppliers purchase these from a free market at prices, more often than not, well below the ceiling or penalty price. 3 Net Metering Keep in mind that the real solar electricity is used within your building as it is generated and this defers you buying its equivalent from the utility. Sometimes, the power generated from the PV system can exceed your needs and the extra is automatically exported to the grid. Since Jan. 1st 2010 every exported kwh you send to the utility grid is compensated at almost the same retail rate you pay for electricity. Formerly, exported power was compensated at the utilities wholesale rate approx. $0.03-$0.06 per kwh. Now in MA the value of your exported kwh is at the retail rate (approx. $ $0.285 per kwh) minus two system benefit charges per kwh of ~ $ to the Massachusetts Renewable Energy Trust administered by the Massachusetts Clean Energy Center of the Department of Energy Resources & ~ $ to the Energy Conservation & Energy efficiency funds administered by the various utilities. The compensation rate is changing as utilities de-couple electricity pricing; new high rate hikes come into effect during the winter of and temporary charges ( such as Storm recovery surcharges) appear and disappear. Consider $0.18 a safe export kwh value for As part of a PV interconnection application and agreement with the utility, we also help you fill out their Schedule Z. This form designates how exported kwhs are credited; most of our customers carry the credit over from the sunny summer months and bank them to reduce their winter month s electric bills, others apply their credits to separate utility accounts. 4 Costly as in relative economic value under present regulations. The externalities not valued under present law are calculable through categories as varied as reduced health care costs, environmental clean up and defense appropriations and more. Properly analyzed, PV generation is a bargain. New as in energy market acceptance. Terrestrial Photovoltaic installations have a long history in Massachusetts going back to the 1970s. 9

10 5. See MA CMR RENEWABLE ENERGY PORTFOLIO STANDARD CLASS 1 ; there is an exception; you can deposit attributes in the DOER Solar Credit Clearinghouse Auction and depending on how the auction clears or fails to clear they gain an extended life to sell in up to three subsequent years. 6. Minting: The process of depositing Attributes on the NEEPOOL GIS to turn them into immediately tradable SRECs. Re- minting: Depositing attributes in the DOER Clearinghouse Auction to create extended life SRECs. 7. A provision added very late in the legislative process to the Green Communities Act of 2008 allowed utilities to own and build up to 200 MW of PV generation, financed through all ratepayers. Utility owned PV capacity counts towards SRECs compliance. Some is built ; utilities can exercise their capacity build out plans quickly and are actively petitioning to accelerate multi MW installations. Utility ratepayers are charged by their utility for project capital costs. Regulators have set provisions for the utilities to confer benefits of these installations back to their customers. 8. MassCEC- PTS has reported that pre PV systems which now want to qualify to sell RECs and report to the PTS monthly must have automatic reporting even if their PV system is under 10 kw in capacity. BPVS is trying to have this policy changed as it is a costly burden for small PV owners, some of whom do not have reliable internet access. Pre 2010 PV owners who wish to increase their PV capacity now face unnecessary complications. Expansion capacity has to be separately metered so REC and SREC tallies are isolated which involves greater expense in power conditioning units, switchgear and solar kwh reporting. We now have customers who ve expanded their systems several times and have three separate solar kwh meters for their original RECs eligible increment, a second for their SRECs I increment and a third for their SRECs II capacity. 9.DOER publishes on its website a list of all SREC eligible PV systems copying information from this statement of qualification that identifies your site by name, the aggregator representing you, system costs and technical details. 10. Most Solar Lease or Power Purchase Agreement firms are or control aggregators/brokers as are some solar contractors. 10