Policy Archives - Sol Systems

LCFS credit prices in California continue to plummet as supply outpaces demand. Current spot prices for immediate delivery are in the low to mid $60s, a ~30 percent drop from prices last quarter.

Similar to past quarters when the California Air Resources Board (“CARB”) held stakeholder convenings, the market did see a slight uptick on pricing following CARB’s November 9, 2022 meeting when pricing was around the $63-69 range. However, the uptick was short lived.

CARB’s Q2 2022 data posted on October 31, 2022 shows an all-time high of credits outpacing deficits with a surplus of 1.35 million metric tons of credits generated in Q2. The credit bank now sits at 11.3 million metric ton credits.

The downward spiral of LCFS pricing over the past year has impacted many stakeholders’ infrastructure development plans as well as LCFS credit monetization strategies. With regards to project buildout, developers and investors have been taking a more cautious approach, either delaying or halting projects altogether. For LCFS monetization, many market participants, particularly those in the electricity pathway, are re-thinking the cost-benefit analysis of utilizing renewable energy credits (“RECs”) to lower carbon intensity (“CI”) scores. In the past, there has been no question of whether purchasing RECs was worth it as the delta between REC purchase costs and LCFS revenue was large enough to make the REC investment pay for itself in multiples (i.e. despite the added REC procurement costs, market participants would generate enough additional LCFS credits from the purchase to come out ahead). As the delta shrinks, purchasing RECs may no longer be worth it. Where that threshold is will differ from participant to participant based on the vehicle type utilized, the energy economy ratio, and other factors. Sol Systems can work with clients to answer any REC related questions and determine what the optimal REC procurement strategy may be. This market dynamic may also put a downward pressure on REC pricing in CA.

This analysis was featured in the November 2022 edition of the Sol Standard, a quarterly newsletter that provides up-to-date pricing data, market analysis, and policy trends to keep clients up to speed on the country’s growing low carbon and clean fuels programs. To subscribe and access past editions of the The Sol Standard, fill out our subscribe form here.

Solar importers need clearer guidelines from U.S. Customs and Border Protection (CBP) under the Uyghur Forced Labor Prevention Act (UFLPA). The UFLPA is the latest in a series of trade interventions with crucial implications for the deployment of solar technologies to take effect in the last year.

Specifically, the UFLPA prohibits imports into the United States of any goods mined or produced using forced labor from the Xinjiang Uyghur Autonomous Region of China. CBP began enforcing the law on June 21, 2022. While the UFLPA targets a broad range of imports, solar panels have been a focus. CBP issued further guidance on June 13, 2022, citing manufacture of polysilicon—a critical component in solar panels—among the sectors with the highest risk of exposure to forced labor in Xinjiang. As of August, enforcement of the UFLPA has already resulted in more than three gigawatts’ worth of module detentions by CBP. Given its influence on the global photovoltaic supply chain, and especially in light of concurrent federal investments made to scale up domestic solar manufacturing, the Act’s enforcement remains critical.

The UFLPA’s reinforcement of existing U.S. regulations against forced labor comes in response to the state-sponsored detainment of more than 1.8 million Uyghurs and other Muslim minority groups in a system of mass internment camps in Xinjiang, China. Having recently navigated a CBP-issued Withhold Release Order (WRO) of a similar nature, solar module suppliers and their consumers are committed to identifying and removing forced labor from their supply chains. The UFLPA, however, heightens the evidentiary standard imposed on U.S. importers by rebuttably presuming that all goods mined, produced, or manufactured “wholly or in part” in Xinjiang or by entities listed on the Department of Homeland Security’s entity list are made using forced labor. Such goods are therefore denied entry into the U.S. unless an importer can “clearly and convincingly” prove that its imports are (i) outside the scope of the UFLPA, so that the presumption does not apply, or (ii) within scope but eligible for an exception. Rebutting the Act’s presumption requires substantive supply-chain documentation that ties every component in a product to a source that is ‎free of forced labor. To that end, importers have so far relied on affidavits from suppliers attesting to the origin of their products while also collecting bills of lading, production records, invoices, and other supporting evidence. CBP should streamline the process for importers providing such information and increase the number of solar panels and critical components that are allowed to pass across U.S. borders.

Raw materials from Xinjiang are found in dozens of supply chains across the agriculture, healthcare, manufacturing, and energy industries; but because nearly half of the global supply of polysilicon comes from Xinjiang, CBP’s enforcement of the Act means that U.S. solar developers will continue to struggle until CBP provides transparent guidance on import requirements and documentation. Similarly to the Department of Commerce’s ongoing circumvention investigation, whose mere initiation put 51 GW of solar capacity and $52 billion of utility-scale investment at risk, the UFLPA is set to prevent as much as 12 GW of solar modules from entering U.S. markets by the end of 2022. According to AnnMarie Highsmith, Chief of Trade for CBP, as of September the agency had yet to receive any applications from importers for what it calls admissibility reviews, or requests to rebut the Act’s presumption using documentation. Instead, Customs has processed several requests for applicability reviews—claims by importers that goods currently detained by CBP have no connection to Xinjiang or restricted entities.

The American solar industry is taking the fight against human-rights abuses seriously. Many companies have reoriented their supply chains and onboarded third-party audit procedures to avoid using polysilicon sourced from anywhere in the Xinjiang region, and with the support of the Biden Administration, the Solar Energy Industries Association (SEIA) has taken steps to turn an internal supply-chain traceability protocol into an industry standard. However, it is essential for CBP to provide clearer guidance and systematic procedures for solar imports.

A new generation of clean energy begins in the United States. As the Inflation Reduction Act of 2022 (IRA) becomes law, we embark on new and historic opportunities for developers, investors, and renewable energy buyers. Numerous analyses demonstrate the clean energy and climate provisions of the IRA will spur economy-wide greenhouse gas emission reductions of 40 percent while beginning to reshore critical manufacturing supply chains. This will allow corporate leaders to accelerate clean energy investments and to make more impactful energy procurement decisions as the IRA begins the process of addressing historical energy inequities in communities across America.

Additionally, the IRA will spur new technological growth which will lead to new clean energy resources and increased project availability for energy buyers across the US. Energy Innovation also found that the IRA could create up to 1.5 million jobs by 2030. Underpinning the success of the IRA is the need to scale the renewable energy sector. Wood Mackenzie estimates that, at a minimum, the IRA will lead to 67% more solar.

*Figure 1. Historical capacity additions and protections under the Act (GW)*

What’s in a Name?

In our last CEO letter, we highlighted the threat that inflation poses to the renewable energy industry while noting the deflationary potential of clean energy. The aptly named Inflation Reduction Act’s monumental investments in clean energy should have a long-term deflationary impact.

What’s in the Law?

Clean Energy Tax Credits

Among other credits, the clean energy tax credits in the IRA maintain the historic standalone solar ITC until 2025 when the credit shifts to technology-neutral. Essentially, after 2025 the IRA tax credits incentivize any method of generating electricity without emitting carbon dioxide (CO₂). This includes stand-alone energy storage, clean hydrogen, and advanced and existing nuclear, as well as domestic manufacturing. Additionally, credit recipients, including solar, now have the option to select either the investment tax credit (ITC) or production tax credit (PTC). We anticipate that most solar operators will continue to prefer the ITC, at least in the initial years. The below illustrates the base ITC and adders available to larger solar projects meeting labor requirements (additional incentives are available for smaller projects, including the ability to consider interconnection costs in calculating total project cost eligible for the ITC). These credits will begin to phase out the later of 2032 or when the electric power sector emits 75 percent less CO₂ than 2022 levels. This will for the first time directly connect clean energy credits to decarbonization goal, and ensure they are available to achieve it.

Important to note that the IRA sets the base ITC at siAlthough we expect that the IRA’s new direct-pay and transferability options will allow new participants without tax obligations, such as electric cooperatives and municipal utilities, to construct renewables, we do not expect the new options to slow appetite for traditional structured tax equity transactions. To begin with, we expect guidance and initial demonstration of the new options to take at least a year, advantaging traditional tax equity investments in the near term. But even over the longer term, we expect structured tax equity financing will remain more attractive to corporate partners because of its lower recapture risk, its ability to monetize depreciation, and the opportunity it provides for projects to be valued at fair market value rather than cost. The chart below provides a high-level overview of the advantages and disadvantages of transferability versus structuring from a sponsor’s perspective.

Beyond the changes in methodology for investors to acquire tax credits, the IRA allows solar projects to elect Production Tax Credits (PTC) instead. This opens the possibility of structuring a PTC investment similar to the PAYGO financing tax equity structure that exists in the wind segment of the market today. Within the solar space, this could provide additional benefit in geographies with high yields and where production is highly predictable.

Implications for Developers

We expect a limited positive impact on current projects given that the 2022 ITC rate has now increased to 30 percent from the expected 26 percent without triggering labor requirements. We expect this 30 percent to extend into 2023 and for 60 days after the IRS issues new guidance, giving near-term projects an unexpected boost. In addition, the new adders available for projects in fossil fuel transition communities “energy communities” and for projects incorporating domestic content will drive needed investment in both. The

Broad Tax Changes that

IRA seeks to drive clean investment in “energy communities, which may be thought of as energy transition communities – communities that have borne the brunt of fossil fuel usage and should not be left behind in the shift to clean energy. Per the IRA, energy communities include:

Brownfield sites,
Areas with high historical fossil fuel employment and currently high unemployment, and
Areas where coal mines and/or coal-fired power plants have closed.

Thus, a strong financial incentive for projects in energy communities will allow them to continue powering America, but with new access to clean energy resources and funding. In addition to the clean energy and climate benefits, the IRA’s investment in energy communities will have untold public health benefits for communities that have been disproportionately impacted for too long.

Clean Energy Tax Credits

Important to note that the IRA sets the base ITC at six percent if new labor conditions are not met, but allows for a step-up to 30 percent if labor conditions are met (the PTC is similarly structured). In order to receive the full ITC (or PTC), prevailing-wage labor requirements must be met for all projects over one megawatt (MW). This includes:

Payment of prevailing wages during construction, as well as for labor on repairs or alterations during the five-year recapture period on the ITC (for projects over one MW).
Use of sufficient apprenticeship ratios, unless demonstrably unavailable.
Additive ITC bonuses would be available for sufficient use of domestic content as well as construction in an energy community. At 10 percent each, a 50 percent ITC is possible for projects that meet both additional criteria. For smaller projects, an additional 10–20 percent is available for solar projects located in certain low-income communities, low-income residential buildings, or on tribal land.
Transmission upgrades would be considered qualifying property for the calculation of the ITC when part of a project under five MW.

Additionally, for the first time the IRA extends “direct pay” of tax credits to non-profit entities for all resource types and for a limited time to all entities for new categories, such as carbon capture and storage (CCS). Direct pay means that qualifying entities may elect to receive a direct payment of the value of the credit, eliminating the need for participation by an investor with a sufficient tax obligation to monetize them. Entities not eligible for direct pay, including for-profit businesses, are allowed a one-time transfer of each year’s eligible credits to an unrelated taxpayer. We will continue to assess the pros and cons of the new transferability provisions as compared to traditional tax equity financing. Transferability will be effective in early 2023, although forthcoming IRS guidance is necessary to answer questions about how it will work.

Broad Tax Changes that Affect Solar Financing

Several general tax provisions have implications for clean energy financing, most notably the new rules regarding calculation of corporate taxes. For taxable years beginning after 2022, the IRA will apply an alternative minimum tax to C-corporations that have an average annual adjusted financial statement income (i.e., “book” income) for any three-year period in excess of $1 billion. The IRA does not change existing depreciation schedules, but bonus depreciation benefits are slated to phase out between 2023 and 2026, which may have longer term impacts on project finance, as discussed further below.

What’s Next?

What is clearer now than ever before is that clean energy will drive domestic climate action and provide new opportunities for renewable energy growth, procurement, and investment. President Biden signed the IRA on August 16, 2022, and now it heads to the Internal Revenue Service (IRS) for implementation and guidance. While the IRA provides a domestic path to begin building a better tomorrow, it is now on the shoulders of the renewable energy community to execute on the tasks ahead of us and to ensure the future we create is one that benefits all.

Biofuels Stakeholders Rejoice with RFS Announcements and Passage of the Inflation Reduction Act

Following several quarters of rollercoaster activity at the federal level related to the Renewable Fuels Standard (“RFS”), there are now several reasons for biofuel market participants to celebrate. First, with regards to the RFS, the Environmental Protection Agency (“EPA”), as part of a consent decree, has agreed to propose 2023 renewable volume obligations (“RVOs”) by November 16, 2022 and final RVOs by June 14, 2023. The consent decree would settle litigation brought by Growth Energy, which sued the Agency for repeatedly missing deadlines on issuing annual RVO mandates. The consent decree was submitted to the U.S. District Court for the District of Columbia on July 22, 2022, and the court is expected to sign off on the decree in the coming weeks. The biofuels industry has long called for the EPA to provide RVOs in a timely fashion as the missed and delayed deadlines cause market uncertainty and negatively impact investment decisions. This decree is one step in the right direction; more importantly, with the EPA setting volumes in 2023, the Agency will be able to set attainable volumes in the first place, streamlining the process considerably.

As the EPA considers upcoming RVOs, there is a strong push from Midwest states for EPA to increase RVO mandates. In a July 19, 2022, bipartisan letter submitted to EPA Administrator Michael Regan, Senators Amy Klobuchar (D-MN) and Chuck Grassley (R-IA) along with 22 of their colleagues, encouraged EPA to consider higher RVOs. They cited the ability of biofuels to reduce fuel prices and greenhouse gas emissions as driving factors for increased mandates. For similar reasons, on July 29, 2022, Senators Klobuchar and Grassley introduced a Senate companion to the House’s Next Generation Fuels Act (H.R. 5089), which would allow the sale of fuels with higher octane levels and greater amounts of ethanol. The legislation is similar to what was introduced in the House in 2021.

“When it comes to ethanol and other renewable fuels, this bill represents the most significant federal commitment to low-carbon biofuels since the Renewable Fuel Standard was expanded by Congress in 2007.” Geoff Cooper, President and CEO, The Renewable Fuels Association

While there is still much to be clarified about how the climate and clean energy incentives in the Inflation Reduction Act (“IRA”) will be deployed, the law is another reason for biofuels stakeholders to cheer. Approximately $500 million in funding is allocated to support buildout of biofuel infrastructure while $18 billion in funding is set aside for climate-smart agriculture, which could help biofuel producers through the production of lower-carbon feedstocks. Other pools of funding may also be available through the IRA’s initiatives targeting rural America. The IRA also extends several key tax credits for the sector (such as the $1/gallon blenders tax credit for biodiesel and renewable diesel, which is extended through 2024) and introduces new ones (such as the technology-neutral Clean Fuel Production Tax Credit for transportation fuel produced and sold in 2025, 2026, and 2027).

Biofuels stakeholders are not the only ones preparing to ramp up transportation decarbonization. EV and hydrogen stakeholders are also going to see funding and incentives from the IRA to build out infrastructure – particularly EV charging – and boost EV adoption across all vehicle classes. While much remains up to the strength of implementation, one thing is for certain – this historic law is setting up the U.S. for an exponential clean energy growth trajectory.

This article was featured in the August 2022 edition of the Sol Standard, a quarterly newsletter that provides up-to-date pricing data, market analysis, and policy trends to keep clients up to speed on the country’s growing low carbon and clean fuels programs. To subscribe and access past editions of the The Sol Standard, fill out our subscribe form here.

Click here to read the Sol SOURCE June 2022.

The Sol SOURCE is a renewables journal that our team distributes to our network of clients and solar stakeholders. Our newsletter contains trends and observations gained through interviews with our team, incorporating news from a variety of industry resources.

Below, we have included excerpts from the June 2022 edition. To receive future Journals, please subscribe or email SOURCE@solsystems.com.

STATE MARKETS

California – California has seen some changes to long-planned energy policy decisions this spring, including potentially keeping its last nuclear plant open while shelving (for now) plans to recalculate net-energy metering (“NEM”). After industry objection, celebrity intervention, and Commissioner turnover, the highly contested NEM 3.0 proposed decision was suspended, likely until after the November election. On May 9, 2022, the California Public Utilities Commission (“CPUC”) issued a ruling formally reopening the NEM 3.0 docket and requesting feedback on a transition approach in the form of a fixed electric bill credit adder on top of the hourly export credits. In addition, the Commission is seeking feedback on whether the successor tariffs should be extended to include community solar as well as the viability of access for renters and low-income ratepayers. Comments are due June 10, 2022, and reply comments are due June 24, 2022.

On April 21, 2022, the California Independent System Operator (“CAISO”) and Western Energy Imbalance Market (“EIM”) announced that cumulative benefits for entities participating in the rapidly growing real-time energy market have exceeded $2 billion, suggesting neither entity intends to halt efforts to expand.

District of Columbia – After considering a range of options, the DC Public Service Commission will allow existing customer-sited solar projects to continue operating on estimated production. However, effective April 1, 2022, all new systems must have a revenue-grade production meter or inverter-based production measurement equipment. This is part of a broader effort to ensure that customers’ REC production can be tracked.

There remains no word yet on nominees for the DC Public Service Commission vacancy, which continues as the DC election heats up. June elections will see competition for Mayor, Attorney General, and several rarely open Council seats.

Florida – On April 27, 2022, Governor Ron DeSantis (R) shocked the solar industry by vetoing a bill backed by Florida Power & Light that was widely expected to gut the rooftop solar industry in Florida (SB1024/HB741). Gov. DeSantis, in several high-profile disputes with other Florida corporations, cited inflation and other cost concerns in his surprise veto. This adds Florida to states that have rescinded (or at least delayed) drastic changes to NEM in recent weeks.

Illinois – Illinois continues working to implement myriad regulatory and other requirements stemming from last year’s landmark Clean Energy and Jobs Act(“CEJA”). After revising the Long-Term Renewable Resources Procurement Plan based on stakeholder feedback, the Illinois Power Agency submitted its final plan to the Illinois Commerce Commission (“ICC”) on March 21, 2022. ICC is expected to issue a proposed order by June 8, 2022, which will provide guidance on future block operations and REC pricing. Per CEJA, the ICC must issue a final order by July 19, 2022. The IPA will be running its second Indexed-REC RFP for electric supply and renewable energy products this fall. The program website and guidebook are valuable resources.

Indiana – Indiana saw the first, but likely not the last, delayed closure of a fossil fuel power plant due to the Commerce investigation that created new uncertainty for the solar industry. On May 4, 2022, the Northern Indiana Public Service Company (“NIPSCO”) announced that the planned shutdown of a coal-fired power plant would be delayed to 2025, citing “uncertainty and delays” in the solar panel industry. NIPSCO representatives stated on an earnings call that they expect the investigation to delay solar projects by six to 18 months. As a result, the utility expects to delay the retirement of two coal‑fired units by two years. NIPSCO previously calculated that replacing its coal with renewables could save customers billions of dollars over three decades.

Maine – Maine continues to attempt to develop a wider variety of clean electricity options in the state while wrestling with its role in the national transmission system. The Governor’s Energy Office is expected to reconvene the distributed generation stakeholder group now that Maine’s legislative session has ended. We expect a straw proposal later this fall to contain more successor program design details in advance of a final report due January 2023. On May 10, 2022, developers of the New England Clean Energy Connect (NECEC) transmission project argued in court against the constitutionality of a ballot measure approved by state voters in November that sought to nullify the project. The NECEC project would carry electricity from Canadian hydropower to the New England grid.

Maryland – While most observers expect next year to be a watershed year for climate and clean energy legislation if the Governorship flips, Governor Larry Hogan (R) allowed the Climate Solutions Now Act of 2022 (SB 528) to become law without signature. The law requires the State to reduce statewide greenhouse gas emissions, establish a net-zero statewide greenhouse gas emissions goal, and develop building energy efficiency and building and transportation electrification requirements.

Massachusetts – The Baker Administration continues to push forward several energy-related items in its last year. On April 15, 2022, the Massachusetts Department of Environmental Protection (“MassDEP”) published proposed amendments to the Clean Energy Standard (“CES”). The proposed amendments include setting the CES alternative compliance payment (“ACP”) and Clean Energy Standard-Existing (“CES-E”) ACP to $35/MWh and $10/MWh respectively for years 2022 through 2050. Comments are due on June 3, 2022, and we expect a final decision in the coming months. On May 20,2022, the Massachusetts Department of Energy Resources (“DOER”) issued an email notice to stakeholders identifying two errors affecting the minted supply of 2021 Clean Peak Energy Certificates (CPECs).

Omnibus energy legislation focused on advancing offshore wind is expected to make it through the legislature before the July 31, 2022 end of session. A conference committee has been appointed to merge HB 4524 (previously HB 4515) and SB 2842. The House version contains specific offshore wind provisions, including tax incentives, grid modernization, and a target of 5,600 MW by June 2027. The Senate version is slightly broader and includes energy efficiency and transportation goals. We likely will not see much movement until July.

On May 24, 2022, the Commonwealth’s highest court ruled Attorney General Maura Healey can pursue a lawsuit charging ExxonMobil with violating state consumer protection laws. Healey, a candidate for Governor, alleges ExxonMobil knew about the threat of climate change but downplayed it publicly while selling fossil fuels.

New Jersey – The Board of Public Utilities (“BPU”) continues to broadly deny extensions for projects unlikely to meet Transition Renewable Energy Credit (“TREC”) deadlines while smoothing the process of moving projects from the TREC to the Administratively Determined Incentive (“ADI”) successor program. On April 26, 2022, BPU issued a Straw Proposal for the Competitive Solar Incentive (“CSI”). Staff will hold three virtual Stakeholder Meetings this summer to discuss the CSI Straw Proposal, with comments due June 20, 2022. On May 18, 2022, the BPU adopted a rule to implement the requirements of Section 38(d)(2) of the Clean Energy Act of 2018, as amended, which establishes a cost cap on certain Class I renewable energy incentives. Additionally, the BPU calculated the Cost Cap for Energy years 2021, 2022 and 2023 and noted that they are not forecasted to exceed the cost cap in 2022 or 2024. In the same order, the BPU also released the megawatt allocations in the ADI for Energy Year 2023 (as a reminder, the energy year and capacity allocations close with new blocks opening on June 1, 2023).

Legislation related to interconnection (S431) and energy storage incentives (S2185) will be heard and voted upon at the next Senate Energy and Environment Committee meeting, which is scheduled for June 6.

New York – New York’s gubernatorial drama continued this spring, with Lt. Gov. Brian Benjamin resigning over alleged campaign finance violations in his previous position. After last-minute legislation to allow him to replace Benjamin on this year’s ballots, Antonio Delgado was sworn in as lieutenant governor on May 25, 2022. A special election to fill his congressional seat will be held at the same time as the August 23, 2022, primary.

On April 14, 2022, the New York Public Service Commission issued a final order approving a new framework for the state to achieve at least ten gigawatts of distributed solar by 2030 (often referred to as the “10GW Roadmap”). The adopted framework includes an investment of $1.5 billion in ratepayer-funded incentives to extend the NY-Sun program. It also adds prevailing wage requirements for projects 1 MWac or greater. NYSERDA released an updated NY-SUN operating plan on May 31, 2022. Incentive programs will officially open on June 7, 2022.

North Carolina – North Carolina has begun to implement HB 951. On May 16, 2022, Duke Energy submitted its proposed plan to the North Carolina Utilities Commission (“NCUC”) as required by HB 951. This plan will be a key component NCUC will use to compose the overall Carbon Plan as required by December 31, 2022.

Ohio – Ohio energy policy continues its recent ambivalence toward clean energy. On March 8, 2022, the Public Utilities Commission of Ohio argued to the Ohio Supreme Court that its approval of the Solar Generation Fund established by 2019’s scandal-mired HB6 was proper. The Ohio Manufacturers’ Association Energy Group has argued the Commission erred in designing the rate mechanism.

The Ohio Public Siting Board is expected to issue new rules this year to require solar setbacks of 100' from roads and 300' from residences. We also expect additional requirements around fencing and vegetative screening, as well as bills to require larger setbacks to be introduced.

Pennsylvania – Pennsylvania’s as-yet unresolvedprimary will see a dramatic gubernatorial contest between Attorney General Josh Shapiro (D), a vocal proponent of solar and other clean electricity, and conservative State Senator Doug Mastriano (R). The Senate race for the seat currently held by retiring Senator Pat Toomey (R), which will help determine control of the U.S. Senate, will see Lt. Gov. John Fetterman (D) versus the winner of a recount between Dr. Mehmet Oz and David McCormick.

After several showdowns between Governor Wolf (D) and the Republican-controlled Legislature, including a last-minute stay on publication, regulations establishing Pennsylvania’s participation in the Regional Greenhouse Gas Initiative(“RGGI”) were published April 23, 2022, setting up a start date of July 1, 2022. Litigation continues.

The PUC’s annual AEPS compliance report includes discussion of the Hommrich lawsuit that invalidated regulations around virtual meter aggregation and contains a recommendation to reform net metering “to curb excessive wholesale generation from being compensated at retail rates…” In the report, the Commission recommends that “the General Assembly consider modifying the structure of net metering by placing reasonable bounds to curb excessive wholesale generation from being compensated at retail rates.”

Virginia – On April 11, 2022, Governor Youngkin signed multiple bills related to renewable energy. SB 502 and HB 1087 allow localities to assess projects 5 MW or less for either Machinery & Tools or Revenue Share tax (not both). The bill does not apply to projects 5 MW or less that were approved by a locality prior to July 1, 2022. SB 537 and HB 206 give localities the option to require developers to replace or preserve existing trees in a particular site. For example, a developer could be required to ensure that 10 percent to 20 percent of their site is covered by tree canopy, depending on how the site is zoned and how many units there are per acre. Trees that are planted have 20 years to grow into a canopy that exceeds 5 feet in height. Trees can be planted elsewhere if there is not enough on-site, but they must be in the same locality.

In March 2022, the Virginia Department of Environmental Quality (“DEQ”) announced that—effective immediately—it would define solar panels as impervious surface areas. On April 14, 2022, DEQ released additional guidance that pushed implementation out to January 1, 2025 for all projects that have not received interconnection approval.

Public comment for the draft Virginia Energy handbook for renewable energy and energy storage development on brownfields and previously coal-mined lands were due on May 23, 2022. A draft copy of the report can be found here. The final report is scheduled to be released by July 1, 2022.

In April 2022, the Virginia Department of Energy and the Virginia Solar Initiative at the Weldon Cooper Center for Public Service at the University of Virginia released the Virginia Solar Survey. The first such survey in Virginia offers data regarding each county and city’s experience with and readiness for solar development.

On April 14, 2022, the Virginia State Corporation Commission opened a docket to establish a self-certification process for DG resources seeking to qualify as low-income projects and consider additional GATS-related questions. Comments are due June 8, 2022.

SOLAR CHATTER

In the wake of the trade complaint brought on by Auxin Solar, the Solar Energy Industries Association (“SEIA”) is projecting the 27 GW expected to be brought online in 2022 could drop all the way 10 GW, with an additional 70 GW over the next three years at risk of failing to come to fruition.
In a late-May study released by the RMI, detailed analysis projected $5 billion in annual savings for electricity customers if the Investment Tax Credit (“ITC”) and Production Tax Credit (“PTC”) were extended and expanded. The study adjusted its model for both recent inflation and fossil fuel price volatility.
Renewables Forward announced the hiring of its first executive director, Chris Nichols, to champion the DEI initiative started by leading U.S. clean energy companies and partners, of which Sol Systems is a founding member. Nichols brings an impressive track record spearheading DEI work from within and outside the clean energy industry.
The solar business landscape is always changing, and May was no different with large-scale developer Borrego announcing the sale 8.4 GW of their solar portfolio along with 6.4 GW of their battery storage footprint. While Borrego moves on from developing, French energy company TotalEnergies announced the purchase of 50 percent of developer Clearway in TotalEnergies’ latest move to increase its role in the U.S. market.
After fits and starts, the Securities and Exchange Commission (“SEC”) recently proposed how public companies should disclose risk from climate change and climate change regulation. Under the proposal, companies would be required to disclose information about climate-related risks that are reasonably likely to have a material impact on their business, results of operations, or financial condition, as well as to disclose certain climate-related financial statement metrics in a note to their audited financial statements. The goal is to require the disclosures necessary to properly evaluate investor risk, the core mission of the SEC. The risks of not doing so are highlighted in a number of fora, including the recent decision allowing Massachusetts’s lawsuit against ExxonMobil under state consumer protection laws to move forward. Massachusetts alleges the company knew about the threat of climate change but downplayed it publicly while selling fossil fuels.
The “social cost” of a pollutant, such as carbon dioxide, quantifies the cost to all of us of adding one more ton of emissions – in other words, how much damage does a pollutant cause. All pollutants have these metrics, but the “social cost of carbon” has proved particularly contentious in the U.S. lately - after numerous attempts to block its use through the courts, the Supreme Court recently declined to take the case, allowing the White House to finalize (and likely significantly increase) the metric. New York State recently completed a similar analysis, and now uses $121 per ton CO₂, significantly increasing the calculable benefits of clean energy and climate programs.
Congress left town for the Memorial Day holiday weekend without meaningful progress on alleviating Senator Joe Manchin’s opposition to passing a reconciliation bill that includes an ITC extension and expansion (all Republicans remain opposed). When Congress returns, the focus will be on the July 4th holiday as a soft deadline to reach an agreement to use reconciliation to pass a party-line climate, energy, and deficit reduction package. We do expect Democrats to use the reconciliation process before the August recess to extend Affordable Care Act (“ACA”) subsidies; if not extended, notice of premium increases would go out just before the November election, hampering an already potentially dismal election for Democrats.

About Sol Systems

Sol Systems is a leading national solar energy firm with an established reputation for integrity and reliability across its development, infrastructure and environmental commodity businesses. To date, Sol has developed and/or financed over 1 GW of solar projects valued at more than $1 billion for Fortune 100 companies, municipalities, counties, utilities, universities and schools. The company also actively shapes and trades in environmental commodity and electricity markets throughout the United States. The company was founded in 2008, is based in Washington, D.C., and is led by its founder. Sol Systems works with its team, partners, and clients to create a more sustainable future we can all believe in. For more information, visit https://www.solsystems.com

Click here to read the Sol SOURCE January 2022.

Below, we have included excerpts from the January 2022 edition. To receive future Journals, please subscribe or email SOURCE@solsystems.com.

STATE MARKETS

California – NEM 3.0 reform creates uncertainty, and likely new hurdles for California solar developers. On December 13, 2021, the California Public Utilities Commission (CPUC) released the eagerly anticipated proposed decision in the NEM 3.0 docket. The proposed decision was left off the docket for the January 27, 2022, meeting, delaying a discussion until at least February – the next open meeting is February 10, 2022, with the agenda published 10 days prior. Turnover at the Commission and a new Chair, as well as increasingly public discord over the proposal, could amplify this delay.

Stakeholder and analyst reactions are varied, but what does seem clear is that if the decision were to be finalized as proposed, California NEM would drastically lower compensation for residential rooftop solar without storage. Given the relatively high penetration of solar in California, electricity is abundant and cheap midday, but the CAISO grid is increasingly strained in the early evening hours when solar production declines but air-conditioning and other high-demand uses remain. The system is a bit “ducked” as it were.

The Proposed Decision’s intent is to incentivize a shift to solar plus storage, and larger-scale solar, in order to reduce demand for high-emitting peak power. Some of the key proposed changes include reducing payments to solar customers whose production exceeds use, adding a monthly “grid participation charge” for homes (but not businesses) that install solar, adding a temporary “market transition credit” to lessen some higher costs for households outside SDG&E territory, requiring homes that already have solar panels to switch from the existing net metering program no later than 15 years after their sy stems were installed (20 years for low-income homes), and creating a “storage evolution fund” to encourage homes and businesses that already have solar to add batteries, creating an “equity fund” of up to $600 million over four years to bring clean energy to low-income and more-polluted neighborhoods.

This could enable homes and businesses to install solar systems up to 150 percent of their electrical demand to help cover future demand from electric cars or electric heating systems (note, California recently required all new single-family and multi-family homes up to three stories high to have a solar photovoltaic (PV) system as an electricity source), and to shift to time of use (TOU) rates. These changes would apply to customers of SCE, PG&E, and SDG&E but not of publicly owned utilities such as the LADWP. Overall, the proposed NEM revisions are a risk to solar developers, specifically rooftop developers that do not develop storage. However, broad opposition is likely to alter the final rulemaking, and the final rule could provide an opportunity to developers of more flexible systems that are able to displace more emissions by displacing dirtier electricity across more hours of the day.

Connecticut – The fate of banked RECs remains technically unknown in Connecticut. Last year, the Public Utilities Regulatory Authority (PURA) proposed several changes to the Renewable Portfolio Standard (RPS), including the ability to change (and possibly eliminate) the number of RECs that could be banked and used for compliance in future years, which would introduce quite a lot of uncertainty and downward price pressure in the market if finalized and upheld against certain legal challenge. We expect a final ruling in 2022. On July 28, 2021, PURA issued a final order to establish a nine-year, statewide Electric Storage Program for all residential, commercial, and industrial customers.

District of Columbia – New solar energy metering requirements could cause DC residents and businesses to pay for more solar. On August 13, 2021, the DC Public Service Commission (PSC) proposed to require all renewable generating facilities, including behind-the-meter generators, to use revenue-grade production meters or inverter-based production measurement equipment, as opposed to the current allowance for estimation from small sources.

The overwhelming majority of comments submitted by the October 13, 2021, deadline recommended that new requirements should only apply to new customers, with many opposing the entire proposal. We expect any final rule to be pushed into the fall of 2022 at the earliest, with a potential for the rule to be re-proposed. The DC PSC is also working to replace Commissioner Willie Phillips, who was confirmed to the Federal Energy Regulatory Commission (FERC) in late 2021. As a national leader and early adopter of urban solar incentives, DC is facing the twin challenges of how to measure small systems while the market shifts away from the 3G used by many older metered systems. These challenges, at the same time as the shift from the central station grid model to a more flexible, two-way grid, provide an opportunity for developers that can offer high-quality data, including to existing systems providing verifiable solar electricity.

Illinois – Governor Pritzker re-opened Illinois to solar development by signing the Climate and Equitable Jobs Act (CEJA; SN 2408) on September 15, 2021 and a trailer bill (HB 3666) that clarified several provisions, including around prevailing wage requirements and high impact business provisions, in November 2021. Notably, the law sets Illinois on a path to 100 percent clean electricity by 2050. The omnibus energy legislation is quite expansive, but importantly for the solar industry, it re-opens and re-funds the previously closed Adjustable Block Program (ABP). CEJA added three new Block categories (solar on schools, community-driven community solar, and distributed generation (DG) that utilizes equity-eligible contractors) in addition to the original Block categories of small DG, large DG, and community solar. The Illinois Power Agency (IPA) formally re-opened the ABP on December 14, 2021.

Outside of the ABP, the law also includes new labor standards that include the payment of prevailing wage for all solar projects that receive renewable energy credits (RECs) from the IPA. Utility-scale projects, which do not qualify for the ABP, will be able to participate in the first Indexed REC request for proposals (RFP) this spring. Stakeholder comments on the IPA’s draft REC contracts concluded on December 17, 2021, and final language is expected early- to mid-2022. In accordance with CEJA, the IPA withdrew the current Long-Term Renewable Resources Procurement Plan (LTRRPP) revision and issued a new draft on January 13, 2022. The draft LTRRPP incorporates changes to the RPS resulting from CEJA and provides additional clarity on topics including the ABP, competitive procurements, and REC eligibility.

Maine – Like a crisp winter sunrise over Acadia, new DG opportunities are coming over the horizon in the Pine Tree State. On November 2, 2021, Maine voters approved a ballot question to require that a two-thirds majority vote is required to approve new major transmission lines, including the New England Clean Energy Connect (NECEC). On November 3, 2021, NECEC developers filed a lawsuit challenging the ballot question.

However, the recently passed federal infrastructure law allows the Secretary of Energy to designate National Interest Electric Transmission Corridors, which would give FERC backstop siting authority to approve projects in the national interest, which may include NECEC. Separately, in 2021, the passage of L.D. 936 required Maine to begin the process of revamping their Net Energy Billing (NEB) program. Notably, the law directed the Governor’s Energy Office to prioritize distributed generation that is sited on previously-developed land, such as brownfields, within a low-to moderate-income community, or directly serving customer load.

The GEO, alongside a stakeholder group, published an interim report on NEB alterations and impacts on December 31, 2021. A straw proposal with concrete successor recommendations will be released in 2022 and a final report will be delivered to the State Legislature in 2023. This effort will hopefully lead to a more equal incentive distribution between large-scale developers and smaller C&I developers who are working to ensure clean solar electricity is a reality in communities that would otherwise not benefit from clean energy.

Massachusetts – Policymakers are moving forward on the region-leading effort to maximize solar deployment in high-density areas and improve the interconnection process in one of the nation’s oldest grids. On September 7, 2021, FERC opened a review of ISO-NE’s rules for requiring grid upgrades to accommodate planned transmission facilities. On October 29, 2021, the Massachusetts Department of Energy Resources (DOER) filed its proposed final Phase 2 version of the 225 CMR 14.00 Renewable Energy Portfolio Standard (RPS) Class I and 225 CMR 15.00 RPS Class II with the Secretary of the Commonwealth’s Office. The Phase 2 version of the regulation contains changes related to biomass. The final version of the regulations along with the associated guidelines can be found here. On November 24, 2021, in Docket 20-75, the Massachusetts Department of Public Utilities (DPU) issued an order establishing a provisional cost allocation program (Provisional Program) to facilitate the interconnection of distributed generation currently in the interconnection queue and facing atypically high interconnection costs.

As a reminder, Docket 20-75 was established primarily to consider cost socialization to reduce interconnection costs faced by developers. While timing is uncertain, we do still expect an additional order on the long-term planning process described in the DPU’s Straw Proposal. On December 30, 2021, the DPU issued a long-awaited order expanding the Solar Massachusetts Renewable Target (SMART) program from 1,600 to 3,200 megawatts (MW). Notably, the DPU rejected utilities’ proposed tariffs and directed them to refile a tariff within 15 business days. The order officially took effect on January 14, 2022.

New Jersey – The solar successor program is finally in place, but over 3,000 TREC applicants hang in limbo as the BPU processes last-minute applicants. After months of stakeholder processes and input, the Board of Public Utilities (“BPU”) released four orders on July 28, 2021, including a detailed solar successor incentive program and the official close of the Transition Incentive (TI) program (August 27th, 2021). The new Successor Solar Incentive Program, “SuSI”, provides incentives for both projects under 5MW (“Administratively Determined Incentive”) and over 5MW (“Competitive Solar Incentive”). The ADI provides fixed incentives for smaller DG projects and added new incentives for public entities, such as schools and municipalities. The program officially opened on August 28, 2021.

The program officially opened on August 28, 2021. At the end of October 2021, the New Jersey Board of Public Utilities (BPU) issued a draft rule proposal on the Class I cost cap calculation and methodology. The cap would be raised to about $950 million, which we expect is plenty of headroom given the cost offsets (carbon and energy value). If the cost cap is breached, the Board would be able to invoke a reduction in the ADI which is currently set to 150 MW.

On November 30, 2021, the BPU held their first stakeholder meeting regarding the design of the Competitive Solar Incentive (CSI) Program that is expected to launch later this year. Stakeholder comments on the design were submitted on December 14, 2021, and stakeholder sessions will continue in January and February of this year. On November 10, 2021, a recently re-elected Governor Murphy (D) signed Executive Order No. 274, 20221, which establishes a new interim greenhouse gas reduction target of 50 percent below 2006 levels by 2030. We expect signature of this near-term target to underpin continued strong solar incentives in New Jersey and increased focus on improving interconnection, a key BPU focus going into the new year.

New York – Like its co-leader in climate action in California, the Empire State is tackling how to maximize the emissions-reduction potential of solar energy, giving a boost to solar with storage over standalone solar projects. On December 17, 2021, the New York State Energy Research and Development Authority (NYSERDA) and New York State Department of Public Service (DPS) released the long-awaited Distributed Solar Roadmap to propose a pathway to achieve 10 GW of distributed solar deployment by 2030. New initial NY-SUN block incentives intended to sustain development through 2022 include (1) Upstate Commercial and Industrial (C&I), Small C&I (< 1 MW) in Consolidated Edison Company of New York (ConEd) territory, Large C&I (> 1 MW) in ConEd territory, and residential projects in ConEd territory. Projects in the queue that have not yet received an incentive are eligible for the new incentives. In addition, NYSERDA is recommending that prevailing wage or project labor agreements be required for all projects over 1 MW.

Despite opposition, the new Customer Benefit Contribution for residential and small commercial customers took effect on January 1, 2022. This charge does not apply to customers that interconnected solar PV systems before January 1, 2022, or to “front of the meter” projects such as community solar. This follows the recent trend, most obvious in the CPUC PD, of states looking to lessen net-metering incentives during prime hours or charge these customers directly for use of the grid. We expect this trend to continue in other states, and we expect to see more attempts to increase the value of solar systems with storage at the expense of “plain solar” going forward.

On November 30, 2021, Governor Kathy Hochul (D) announced that NYSERDA finalized contracts with Clean Path NY (CPNY) and the Champlain Hudson Power Express (CHPE) projects to connect cleaner electricity from upstate New York and Canada to New York City. NYSERDA will offer renewable attributes from these projects for voluntary purchase. These contracts have been submitted to the PSC for approval and are subject to a public comment period through February 7, 2022. Delivery is expected to begin in 2025 for CHPE and 2027 for CPNY.

North Carolina – Large clean energy buyers took a hit on October 13, 2021, when Governor Roy Cooper signed House Bill 951, Energy Solutions for North Carolina, which includes a number of provisions aimed at increasing clean energy deployment and reducing carbon emissions in the state, but largely excludes corporate procurements. The bipartisan law sets a carbon emissions reduction target of 70 percent by 2030 and carbon neutrality by 2050. The law also provides provisions for utility procurement but falls short of meeting the needs of businesses and other large energy consumers. The new law incentivizes utility ownership over competitive markets and flags a need to revise future policy to better align utility and independent developer interests with large renewable energy buyers to maximize deployment and emissions reductions.

Ohio – Final word on HB6 is still in limbo amid a heated legal battle with multiple legislative solutions on the table. The FirstEnergy HB 6 legal battle continues to dominate Ohio politics and energy policy discussions after this year’s passage of SB 52. On July 12, 2021, Governor DeWine (R) signed SB 52, which subjects large (over 50 MW) wind and solar projects to review by County Commissioners before Ohio Power Siting Board (OPSB) review. The legislation also allows County Commissioners to establish restricted areas where wind and solar projects are prohibited, subject to local referendum; adds members to the OPSB from affected counties; and requires developers to submit decommissioning plans when applying to OPSB. Ohio continues to be a big opportunity for large-scale solar and wind developers given their connection to PJM and MISO, as well as availability of former fossil interconnection sites. We see SB 52 as codifying good community engagement practices for developers and adding a manageable number of steps to the siting process.

Pennsylvania – A number of factors continue to dampen the otherwise-significant investment potential in the Commonwealth, including hostility to renewables from the Republican-controlled Legislature, flatlining of the Alternative Energy Portfolio Standard (AEPS) in 2021, and continued discord over RGGI. Pennsylvania has become a key state in the discussion of how to ensure proper decommissioning of solar facilities, particularly on agricultural lands. HB 2104 would establish state-wide decommissioning requirements for projects over 3 MW with a phased-in approach to posting financial assurance, which may be in the form of an escrow account or bond, and potentially letters of credit. However, two elements remain unresolved: First, the bill does not explicitly require the inclusion of salvage value in the calculation of decommissioning costs to reduce the amount of financial assurance required (it also does not exclude its use in the calculation or acquisition of a bond). Second, the bill requires that no more than 20 percent of a project’s total mass may be landfilled. Some have misinterpreted this as a requirement to recycle the remaining 80 percent, but the wind industry is particularly concerned that many of their components cannot yet be recycled and require ongoing parts replacement throughout the life of a project. Discussions on decommissioning renewables projects continue in both Chambers (the Senate is SB 284). Also this week, the bill (SB 945) to require the Commonwealth to sell (rather than retire) SRECs associated with solar procurements passed out of Committee, although we do not expect it to become law this session.

The Republican-controlled Legislature continues its attempts to block Pennsylvania’s participation in the Regional Greenhouse Gas Initiative (RGGI), although Governor Wolf (D) has successfully blocked their efforts. However, given the Legislative Reference Bureau’s interpretation of regulatory publication requirements, Pennsylvania’s participation will slide to at least April 1, 2022, and potentially July 1, 2022 (auction participation and revenue may be able to occur earlier).

Virginia – The fate of the Virginia Clean Economy Act (VCEA) and solar development in the Commonwealth teeters on Democratic control of the State Senate. On November 2, 2021, the GOP flipped all three statewide executive offices as well as the House of Delegates, while Democrats retained the Senate. This election carried national implications as it is widely considered a bellwether for the 2022 national midterms. Governor Youngkin (R) has announced initial appointments indicative of a hostile posture to clean energy, including announcement of his intention to nominate former EPA Administrator Andrew Wheeler to lead the Department of Natural Resources. He has also stated a desire to reverse Virginia’s recent participation in the RGGI, although this would require legislative approval. All this leads us to watch Virginia particularly closely and ramp-up advocacy efforts to protect the recently-enacted VCEA.

Regional Round-Up

PJM – On December 15, 2021, PJM released a study looking at how to manage a high-renewables grid and found that PJM would better handle higher renewables penetration with strategic regional transmission expansion, grid-enhancing technologies, and storage. PJM also continues to move forward to reform the interconnection queue process. The goal of the reformed process is much faster interconnection agreements – currently, the process averages four years and PJM is targeting to reduce this to two years by shifting to a “cluster” versus “serial” review. While this transition will be rough for many individual projects, this switch should alleviate a significant hurdle to larger solar projects in the most populated area of the country.

Regional Greenhouse Gas Initiative (RGGI) – The December 2021 auction cleared substantially higher, at $13/allowance, just triggering the cost containment reserve (CCR), even as confusion swirled around the timing of Pennsylvania’s participation and Governor Youngkin’s desire to withdraw Virginia. This was potentially the last auction without Pennsylvania’s participation.

Transportation & Climate Initiative (TCI) – In late November 2021, states participating in TCI – a cap-and-invest program covering liquid transportation fuel (e.g., diesel and gasoline but not natural gas) – abandoned the program after Connecticut Governor Ned Lamont (D) and Massachusetts Governor Charlie Baker (R) withdrew.

TRADE UPDATE

On December 9, 2021, the U.S. International Trade Commission formally recommended Section 201 tariffs be extended another four years past the current endpoint in February. President Biden will make the decision before the current tariffs expire February 7, 2022. The parallel challenge to the bifacial exemption is continuing, and our trade groups are optimistic that will persist even if the tariffs are extended.   
On December 23, 2021, President Biden signed the Uyghur Forced Labor Prevention Act.  The law aims to prohibit imports made using the forced labor of ethnic Uyghur Muslims in China, which the U.S. and other nations have termed an ongoing genocide. While the Section 201 tariffs were not in response to forced labor concerns, they have become politically entwined and passage of this law may relieve some pressure to extend the tariffs despite their impact to the President’s clean energy goals. 
Meanwhile, global supply chains continue to challenge the solar industry. While the price to install new solar continues to be relatively cheap compared to previous decades, supply chain disruptions led to increases in system pricing across all sectors of the industry. Utility-scale systems with single-axis trackers were among the worst hit, with system pricing increasing by 9 percent year-over-year in 2021.  Rystad Energy recently estimated shipping and equipment costs could postpone or cancel more than half of worldwide utility-scale solar projects planned for 2022.

SOLAR CHATTER

On December 8, 2021, President Biden signed an executive order requiring achievement of net-zero greenhouse gas emissions from federal electricity usage, vehicle fleets, buildings, operations and procurement activities by 2050. The EO uses the scale and procurement power of the federal government to achieve emissions reductions. The EO directs federal agencies use electricity from carbon-free sources by 2030, which it said will spur an additional 10 gigawatts of clean energy demand.
On December 7, 2021, more than 50 large electric utilities announced the National Electric Highway Coalition (NEHC) to install EV fast-charging infrastructure along major U.S. highway corridors by the end of 2023, in an effort to alleviate consumer range anxiety. The coalition is led by the Edison Electric Institute (EEI), which anticipates 22 million EVs in the U.S. roads by 2030, requiring more than 100,000 fast chargers.
SEIA and Wood Mackenzie Power & Renewables released their Solar Market Insight Report for Q4 2021 last month. Utility-scale solar set another record year with 3.8 GWdc of installations and over 6.1 GWdc of new utility-scale solar power purchase agreements signed in Q3 2021 alone, representing 46 percent growth over the same period last year. Continuing the trend of recent years, corporations, municipal utilities, and off-takers looking to invest in cleaner power generation were principally responsible for driving this growth.
To maximize the benefits of solar paired with agricultural land, The National Center for Appropriate Technology (NCAT) launched the nation’s first ArgiSolar Clearinghouse to connect farmers, ranchers, and land managers to solar developers to provide information and tangible benefits to increase the co-location of solar and farmland. 
Nebraska became the 20^th state to commit to 100 percent clean electricity by 2050. The Nebraska Public Power District (NPPD) Board approved the decarbonization effort alongside Omaha Public Power District (OPPD) and Lincoln Electric System (LES), meaning that almost every Nebraskan will receive electricity from an energy supplier that has pledged carbon neutrality.

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The Sol SOURCE – January 2022

STATE MARKETS

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TRADE UPDATE

SOLAR CHATTER

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Expanding Our Reach: Sol Systems Now Offering MA Class I REC Management throughout New England

Explore sustainable energy solutions with Sol Systems

Explore sustainable energy solutions with Sol Systems