Bidder Frequently Asked Questions (FAQs) for the 2016 Massachusetts RPS Solar Credit Clearinghouse Auctions Auction Date: July 29, 2016 Issued by: The Commonwealth of Massachusetts Department of Energy Resources 100 Cambridge Street, Suite 1020 Boston, MA 02114 http://www.mass.gov/doer Issued on July 6, 2016 Administered by: EnerNOC, Inc. 100 Front Street, 20th Floor Worcester, MA 01608 Bidder – SREC Auctions Frequently Asked Questions Contents 1 Frequently Asked Questions Overview ............................................................................ 1 2 Auction Related Questions .............................................................................................. 1 3 SREC Policy Related Questions ...................................................................................... 7 Issued on July 6, 2016 Page ii Bidder – SREC Auctions Frequently Asked Questions 1 Frequently Asked Questions Overview In the course of conducting the 2016 Solar Credit Clearinghouse Auctions, the Massachusetts Department of Energy Resources’ (DOER) administered an online question and answer process. This document generalizes and summarizes some of the frequently asked questions (FAQs) received through the online question and answer process. All relevant documents referenced in this FAQ document, including the SREC Auction Notices for the 2016 Solar Credit Clearinghouse Auctions and Qualification Applications for the 2016 Solar Credit Clearinghouse Auctions can be found in an electronic format at the following website (Auction Website): https://www.wesplatform.com/WebPortal/Public/Announcement.aspx?ID=7Pi67GLu9ng%3d Please note: These Questions and Answers are provided to assist applicants in understanding the auction process and the corresponding requirements. However, all the information needed to participate in the 2016 SREC Auctions can be found in the SREC Auction Notices. Please review the SREC Auction Notices carefully before completing the Qualification Applications. 2 Auction Related Questions Questions and answers provided in this section relate to the auction, clearing, and settlement procedures. 1. SREC Auction Notice Section 6.3 states "If there is an odd number of SREC deposited a random number generator will be used for any ties." Please describe the methodology and seed selection method used for this random number algorithm. Bids are evaluated by their assigned random number that is generated by a computer. The Auction Platform utilizes the built in random number generation capabilities of Microsoft.net. Specifically, the Auction Platform employs the random number generator implemented in Microsoft.net’s Random class. Microsoft.net’s random number generator, seeded with an integer representing the current time and date from the computer’s system, will produce a sequence of random numbers that meet the statistical requirements for randomness. 2. The SREC Auction Notice doesn't clearly state how partial SRECs are handled. For example, if only 10% of SRECs clear, then systems that entered any number of SRECs not a multiple of 10 would have partial SRECs that cleared, e.g. a system that entered 9 SRECs would clear .9, which is not possible. Another system that entered 1 SREC would clear .1, again not possible. Will you treat both these systems the same and apply your random number algorithm, i.e. the system that entered only 1 SREC has just as much chance of selling 1 SREC as the system that entered 9 SRECs? Note that this would create a large disparity that discriminated against larger system; in the above example the small depositor would have a 10% chance of selling 100% of their SRECs while the larger depositor would have a 10% chance of selling only 11% of their SRECs. SREC Auction Notice Section 5.1 Auction Overview describes the SREC settlement process. Figure 6, SREC Tiebreaking Process Example, illustrates the answer to this question. In this example cumulative demand exceeds the quantity of SRECs offered for sale; however, even if cumulative demand is less, the procedures are essentially the same. Issued on July 6, 2016 Page 1 Bidder – SREC Auctions Frequently Asked Questions As stated in the notice, if cumulative demand is less than the quantity of SRECs offered for sale after the third auction, each bidder’s bid is awarded a pro-rata share of the total SRECs offered for sale proportional to each of the bidder’s bid quantity, relative to the total cumulative demand. As shown in the figure, bidders who submit small bids may receive no awards. In this example, the pro-rata share of a small bid may be rounded down to zero (0) resulting in no awards to that bidder. This same procedure will be utilized for SREC sellers. If cumulative demand is less than the quantity of SRECs offered for sale after the third auction, each seller’s offer quantity is awarded a pro-rata share of the total SRECs offered for sale proportional to each of the seller’s offer quantity, relative to the total available supply. Bidders and sellers that only enter only 1 SREC may not receive an award, due to rounding, if aggregate demand is significantly less than aggregate supply. The Auction Platform does allow bidders to submit an unlimited number of bids; however, the more bids submitted the greater the potential for unpredictable rounding outcomes. 3. If none of the auctions clear, are the SRECs sold on a pro-rata basis (e.g. if demand is only equal to 50% of supply, 50% of a depositor’s SRECs will be sold). Please see the planned outcomes for each of the SREC I and II auction rounds. 1. If cumulative demand is insufficient to clear the quantity of either SREC I and/or II offered for sale, then the said 2017 SREC I and/or II Auction(s) is deemed “void” and the shelf life of the SRECs is increased to three (3) years after the year in which the SRECs were generated (enhancing their market value), and a second 2017 SREC I & II Auction is repeated within three (3) business days. 2. If the cumulative demand in the second 2017 SREC I and/or II Auction is still insufficient to clear the quantity of SRECs offered for sale, then the second 2017 SREC I and/or II Auction is deemed “void”, and the Minimum Standard for the next Compliance Year (the year subsequent to one in which the SRECs were generated) is adjusted for a second time by DOER by increasing the MWh obligation by the total volume of SRECs that were deposited into the Auction Account. The 2017 SREC I and/or II Auction is repeated a third time within three (3) business days with the shelf life remaining at three years. 3. If the third (and final) auction for 2017 SREC I and/or II does not clear, the SRECs are allocated to bidders in a pro-rata manner. This means that each bidder receives the quantity of SRECs for which it had bid based on a pro-rata distribution of from the SRECs that had been deposited from each GIS Asset. Each SREC depositor will sell an equal percentage of SRECs. The remaining (uncleared) SRECs are returned to the Owners or Operators of the GIS Assets that made the deposits, and those Owners or Operators can then sell those SRECs for compliance in any of the three (3) Compliance Years subsequent to the year in which they were generated. If neither of the first two auction rounds clear, then no SRECs are transacted. If the third auction also fails to clear, the SRECs will be sold on a pro-rata basis. 4. The SREC Auction Notice provided information about the settlement and wire transfer process for bidders, but there isn’t anything about how SREC depositors should indicate the bank account to which funds should be wired after the auction Issued on July 6, 2016 Page 2 Bidder – SREC Auctions Frequently Asked Questions for each NEPOOL account. Please provide information about how to tell the Auction Platform where to wire the funds? Since a depositor cannot remove SRECs from the NEPOOL clearinghouse auction account once the SRECs are deposited, it is important to know before what the process is for getting paid for them after the auction. After the auction clears, bidders have ten (10) days to make payment. Within ten (10) days after receipt of payments World Energy will deposit funds from the sale of the SRECs into depositor’s or aggregator’s bank accounts. Depositors need to submit the SREC Auction Proceeds Transfer Form to World Energy providing their bank account information. . The SREC Auction Proceeds Transfer Form has been posted on the Procurement Website and is also contained in Appendix A of the SREC Auction Notice. 5. There are a lot of materials on line for bidders in the upcoming MA SREC Auction. However, as depositors into the auction, is there any information we have to provide in order to be set up to receive the incoming funds from bidders? Will we be asked for bank transfer information at a later date? Do we need to submit any application materials to become eligible? Please see the response to Question 4. 6. Do depositors have to submit the Qualification Application or only the bidder? When is it due? Depositors do not have to submit the Qualification Application. Bidders must fill out the Qualification Application and submit it to the SREC Auction Manager by due date listed in the SREC Auction Notice. However, depositors do need to fill out and submit the SREC Auction Proceeds Transfer Form, which can be found on the Procurement Website and in Appendix A of the SREC Auction Notice. 7. When do the depositors receive the proceeds of their SREC sales in the auction? The date will vary depending on which round ends the auction. Bidders have ten (10) days to settle their purchases and within ten (10) days after that date, depositors and aggregators will receive payment for their SRECs. Auction proceeds will be disbursed to system aggregators, if applicable, and it will be up to the aggregator to distribute the funds to individual asset owners. 8. Can market participants, even if they are not bidders, watch the auction as it takes place? Essentially will there be the ability to watch bids accumulate (or not accumulate) during the auction itself? No, neither bidders nor market participants can watch the auction as it takes place. Only the Auction Manager and DOER will be able to view the auction as it takes place. Bidders will only be able to see the bids they have placed in the RFP. Issued on July 6, 2016 Page 3 Bidder – SREC Auctions Frequently Asked Questions 9. Will the SREC Auction manager publicize the names of bidders registered for the auction prior to the auction beginning? No, to protect against possible collusion, the names of registered bidders will not be made public. 10. How soon after the auction occurs will the final results be publicized? For an auction round that does not clear, the next round of the auction must be conducted, per DOER regulation, within three (3) business days. To accommodate this schedule, the results of the Auction (i.e., whether it clears or not) will be publicly announced within 24 hours after the conclusion of the Auction. 11. How the results of the Massachusetts SREC auction will be disclosed? Auction results will be posted on DOER’s website www.mass.gov/doer. 12. What year of compliance obligation is the basis for the limit between need collateral and do not need collateral? The compliance year obligation that will be used to determine whether a bidder needs to submit financial security is the prior year’s compliance obligation. 13. What is the difference, and where can we find the GIS Account Number, The Company ID number, The GIS Asset ID #, and the Unit ID #? The information required on Qualification Application Form 3 – Evidence of a NEPOOL GIS Account is the following: Company Name of the NEPOOL GIS Account Holder Company Identification Number of the NEPOOL GIS Account Holder NEPOOL GIS Account Contact Information necessary to complete this form must be obtained from the NEPOOL Generation Information System (NEPOOL GIS). 14. Can you confirm that the maximum amount of security required to be posted is $100,000? The requirement to post financial security as well as the amount depends on whether the Applicant is a licensed RES in Massachusetts with a RPS compliance obligation and whether it is bidding in excess of its actual compliance obligation. Financial security requirements for each of the three (3) scenarios are as follows: • If the Applicant is a licensed RES in Massachusetts with a RPS compliance obligation and is not bidding in excess of its actual compliance obligation, then financial security does not need to be posted. Such Applicants will receive a financial security credit equal to their actual compliance obligation based on the amount of load they served in the previous compliance year. Issued on July 6, 2016 Page 4 Bidder – SREC Auctions Frequently Asked Questions • If the Applicant is a licensed RES in Massachusetts with a RPS compliance obligation and is bidding in excess of its actual compliance obligation, then financial security must be posted to cover its excess bid amounts. Such Applicants will also receive a financial security credit equal to their actual compliance obligation plus any additional financial security that was posted. • If the Applicant is a non-Retail Electric Supplier in Massachusetts without a RPS compliance obligation, then financial security must be posted to cover its full bid amounts. In order for an Applicant, who is required to provide financial security, to participate in an SREC Auction, financial security, in United States dollars (USD), must be received from the Applicant no later than date and time listed in the SREC Auction Notice. The amount of financial security submitted or credited to the Applicant, in the case it is a licensed RES in Massachusetts with a RPS compliance obligation and is not bidding in excess of its actual compliance obligation, will be set as such Applicant’s financial bidding limitation in a SREC auction. There is no maximum or minimum financial security required to participate. Each bidder must independently determine how much financial security to provide depending upon its own unique circumstances. 15. Does posting the maximum amount of security allow you to bid for as many SRECs as you wish? Please see the response to Question 14. Questions for the 2016 Auctions for SREC’s I & II 16. Is the Financial Security amount required to be filled in on the application due on July 13th or do we have until July 22nd (the date the financial security is due) to determine the exact amount that we’ll be sending? The response due on July 13th is for each bidder to indicate a non-binding amount of financial security they anticipate posting. It provides us with an expectation of what is to be posted. Bidders are able to post a different amount of financial security up to the July 22nd, so long as the amount is within the parameters stated in the respective auction notice. 17. Are we also able to post no financial security if we decide by the 22nd not to participate in the auction (even if we indicated a larger amount that we initially planned to post)? Yes, please see the response to question 16. Issued on July 6, 2016 Page 5 Bidder – SREC Auctions Frequently Asked Questions 18. Per the email from the DOER on July 6th, Bidders without a retail obligation are limited to posting a maximum of 10% of the total auction volume. This is a change from last year. Can you confirm that this is the case? Effective prior to the 2015 DOER SREC I auction, Bidders without compliance obligations may only post financial security in an amount up to 10% of the value of the total auction quantity. Bidding limitations would then be enforced to allow Bidders to submit bids for quantities valued at or below their bidding limitation. Bidders will not be able to submit bids in excess of their bidding limitation and, therefore, could not be awarded SRECs in excess of their bidding limitation. 19. If a Retail supplier’s previous year’s compliance obligation that is greater than the total volume of the SREC auction, can they bid for the total volume of the auction without having to post financial security? Can they bid in excess of the total auction volume? Bidders with compliance obligations may bid up to the full auction quantity (depending on the assigned compliance obligation and whether or not additional financial security is posted). To answer your first question; yes, an entity with a greater obligation than the total volume in the SREC auction can bid on the total volume without having to post financial security. For the second question; no bidders will be able to submit bids for quantities in excess of the total auction quantity. 20. We intend on taking part of both SREC auctions. Do we have to submit two Qualification Applications? One for each of the SRECs? Yes, bidders are required to submit an application for each auction they wish to participate in. In the event a bidder intends on participating in both SREC I and SREC II auctions, an application for each is required to be submitted. 21. Assuming we are told our load is 10,000 MWh and given that the percentage of SREC IIs for next year is 0.7851%, for this example, our SREC II requirement in 2016 will be 79 SREC IIs. Should I decide to bid for more SREC IIs then the 79, may I bid for 10% of the total of 66,440 or only (66,440 – 79 = 66,361)? In other words, do I need subtract my required SREC II obligation from the auction total and then can only bid on the 10% of the remainder? You do not need to subtract the compliance quantity from the total auction quantity when determining the maximum amount of financial security that may be posted. The additional financial security would be handled independently and could be up to 10% of the value of the total auction quantity. Issued on July 6, 2016 Page 6 Bidder – SREC Auctions Frequently Asked Questions 3 SREC Policy Related Questions Questions and answers provided in this section relate to the auction, clearing, and settlement procedures. 1. How much will DOER adjust the SREC obligation in the second auction if the first auction fails? The SREC compliance obligation is adjusted before the first round of the auction, and again if the second auction fails. The number of SRECs that are added to the obligation each time is equal to the number of SRECs that were deposited into the auction account. For the 2013 Solar Credit Clearinghouse Auction, 38,866 SRECs were deposited into the auction account. For the 2014 Solar Credit Clearinghouse Auction, the number of SRECs deposited into the auction account will be announced on Tuesday, June 17, 2014. In the first auction, if the bid volume is insufficient to clear the volume of available Re-minted Auction Account Attributes, then the shelf life of the Re-minted Auction Account Attributes is increased to three years (enhancing their market value), and the second auction is held. If the bid volume in the second auction is insufficient to clear the volume of the available Reminted Auction Account Attributes, then the SREC obligation in the new Compliance Year is re-adjusted by increasing the MWh obligation by the total volume of SRECs that were deposited into the Auction Account. The auction is repeated with the shelf life remaining at three years. If the third (and final) Auction does not clear, the Re-minted SRECs deposited in the Solar Credit Clearinghouse Auction Account shall be allocated to the bidders in a prorated manner so that an equal percentage of Re-Minted SRECs are allocated from each Generation Unit that deposited SRECs. The remaining Re-Minted SRECs will be returned to the depositor with their 3-year shelf life. Issued on July 6, 2016 Page 7 Bidder – SREC Auctions Frequently Asked Questions 2. How will reminted SRECs be designated in NEPOOL so that market participants know they are "reminted" SRECs? The re-minted SRECs will be flagged in NEPOOL GIS to denote the extended life. Specifically, the RPS designation goes from “MA Solar Carve-Out Unit” to “MA Auction Solar Carve-Out Unit”. This new designation allows the re-minted SRECs to maintain the additional two or three year life span in NEPOOL GIS (depending on which round the auction clears), and differentiates the re-minted SRECs eligible to be banked multiple years vs. the SRECs that cannot. The re-minted SREC will maintain the original serial number. 3. Can SRECs deposits be made up until June 15? Yes. Questions for the 2017 Auctions for SREC’s I & II 1. What will happen if the SREC I and/or II auctions do not have sufficient demand to meet the supply? Each auction round has a different protocol. Below I have copied and pasted the information directly from the “SREC I and II Auction Notice” detailing the procedure for each of those instances: Figure 1 displays the clearing process for the 2017 SREC I & II Auction(s). Figure 1: SREC I & II Auction Clearing Process 1. If cumulative demand is insufficient to clear the quantity of either SREC I and/or II offered for sale, then the said 2017 SREC I and/or II Auction(s) is deemed “void” and the shelf life of the SRECs is increased to three (3) years after the year in which the SRECs were generated (enhancing their market value), and a second 2017 SREC I & II Auction is repeated within three (3) business days. 2. If the cumulative demand in the second 2017 SREC I and/or II Auction is still insufficient to clear the quantity of SRECs offered for sale, then the second 2017 SREC I and/or II Auction is deemed “void”, and the Minimum Standard for the next Compliance Year (the Issued on July 6, 2016 Page 8 Bidder – SREC Auctions Frequently Asked Questions year subsequent to one in which the SRECs were generated) is adjusted for a second time by DOER by increasing the MWh obligation by the total volume of SRECs that were deposited into the Auction Account. The 2017 SREC I and/or II Auction is repeated a third time within three (3) business days with the shelf life remaining at three years. 3. If the third (and final) auction for 2017 SREC I and/or II does not clear, the SRECs are allocated to bidders in a pro-rata manner. This means that each bidder receives the quantity of SRECs for which it had bid based on a pro-rata distribution of from the SRECs that had been deposited from each GIS Asset. Each SREC depositor will sell an equal percentage of SRECs. The remaining (uncleared) SRECs are returned to the Owners or Operators of the GIS Assets that made the deposits, and those Owners or Operators can then sell those SRECs for compliance in any of the three (3) Compliance Years subsequent to the year in which they were generated. 2. How do I calculate my RFP compliance obligations for this 2017 MA DOER SREC Auction? Each Retail Electric Supplier (RES) in Massachusetts will have a RFP compliance obligation based on their load service for the year. Please see the example below: LSEs 2016 Load (MWh) 2017 Minimum Standard RES Example A RES Example A 1,000,000 1,000,000 1.6313% 2.8628% Requirement (SREC qty) 16,313 28,628 Category (SREC) SREC I SREC II I will email to each entity with their RPS compliance obligations once calculated by the MA DOER. 3. Is the Qualification Application a binding document? If we choose to alter the amount of financial security that we deposit, will it be an issue? No, the Qualification Application is not a binding document. Please email the [email protected] if you choose to submit a different amount of financial security than original indicated. Issued on July 6, 2016 Page 9
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