Analysis of New Hampshire RPS for Class I renewables

Q.        Please explain your assertion that 'many of these RECs are sold out of state'.

A.        Total quantities and percentages of NH Class I RECs must be understood in the context of a regional market. NH Class I RECs can be used for RPS compliance in several New England states. Thus, many more RECs are actually created in NH than are reflected in the state's RPS compliance figures. Of the six projects listed above, Lempster, Alexandria Indeck and Berlin BioPower[1] are likely the only facilities selling their RECS to in-state service and energy providers. In contrast, Granite Reliable Wind has two long-term power purchase agreements (15-20 years) with Vermont utilities[2] to sell up to 82% of its energy, capacity and RECs. Groton Wind has a signed agreement with Massachusetts utility, NSTAR, to sell all of its energy, capacity and RECs for a term of 15 years. When New Hampshire elected to lower its Class I alternative compliance payment (ACP) to $55 beginning in 2013, Class I qualified projects not under contract were incentivized to sell their RECs in states offering higher ACPs.

The ACP for Class I RECs in Rhode Island and Massachusetts is currently $65.27.  As long as these states have a deficit of Class I REC's , their REC markets will prove more attractive for NH project owners. According to the Massachusetts RPS & APS Annual Compliance Report for 2010 (published January 2012), more than 90% of Massachusetts' 2010 RPS Class I compliance was satisfied by out-of-state resources. Of that, 12.1%  or 282,308 MWh were produced by New Hampshire projects[3].

Looking further out, there are currently several substantial requirements for New England distribution utilities in MA, RI, and CT to add significant amounts of new generation in the next few years using long-term contracts. The Massachusetts Green Communities Act currently requires 7% of RPS compliance using contracts. Recent proposed changes in the Connecticut RPS, if signed into law, will require 4% of the state's RPS load to be satisfied with contacts. Rhode Island mandates 90 megawatts be under contract representing a significant portion of the state's RPS requirement. Both Antrim Wind LLC and Timbertop LLC reported they were shortlisted for RFPs issued by Rhode Island utilities Such legislative mandates in other New England states would continue to pull Class I RECs away from New Hampshire, particularly wind energy RECs. Other changes in the RPS laws in Massachusetts and Connecticut seek to lower or phase-out wood biomass in the next few years. If fully realized, Class I biomass RECs will likely return to New Hampshire, however wind, energy projects proposed to be built in New Hampshire are expected to satisfy RPS laws out-of-state.

TABLE 2

Table 2 estimates the number of RECs produced by New Hampshire facilities and matches the production to the RPS Class I requirement for the period from 2013-2018. By 2014, Berlin BioPower alone, will supply New Hampshire's Class I REC requirement. Barring mitigating changes to the Massachusetts RPS policies for biomass, Shiller will return to New Hampshire beginning in 2016 and further add to the state's supply.