Initial Joint Proposal of Constellation Energy, the Solar Alliance, and RESA to Improve Pipeline Transparency November 2, 2011

The Need for Transparency in the Solar Project Pipeline This Joint Coalition believes a new reporting process that promotes transparency would significantly decrease market volatility In response to these inefficiencies, these diverse stakeholders came together: Causing market uncertainties, ineffiencies and damage to solar development: SREC Volatility – Difficult to accurately predict future supply Developer, Investor, and Retail and Wholesale Power Provider Uncertainty Currently, tracking solar projects in development is opaque and inefficient Information comes from easily obtained and held SRP registrations -- artificially inflates solar supply views

SREC Volatility From SRECTrade.com

Proposed New Reporting Requirements Reporting Step 1: As part of SRP registration, developer must attest to site control in the form of a contract with regulatory and financing contingencies and grid supplied projects must include a signed Interconnection Service Agreement LOI should not meet this requirement Reporting Step 2: Projects must report to the Market Manager within thirty days of having obtained all applicable construction and environmental permits or interconnection approval Must file such permits or approvals with the market manager Reporting Step 3: Projects must report to the Market Manager within thirty days of construction start Defined as when work crews arrive on-site for site preparation Reporting Step 4: Market Manager should indicate which projects have secured participation in an EDC SREC Finance Program or the Solar Loan Program

Principles of Transparent Reporting System 1.The system should minimize administrative burdens for all market participants, including large and small developers, retail and wholesale providers, utilities, and the market manager 2.Reported information must be publically available a.Existing Market Manager should update its current database to be more accessible and searchable b.Updated in a timely and consistent manner 3.Existing Market Manager should amend current SRP Requirements to include this proposal’s recommendations 4.Transparency is best achieved through clear and enforceable reporting requirements that cannot be “gamed”

Implementing a New Market Manager: Administrative Details 1.Joint Parties have agreed solar projects should be assessed a small fee in proportion to their size to cover the costs to implement and maintain such database 2.Current Projects should be granted three month grace period to file new reports 3.All solar projects excluding residential should comply with reporting requirements *Residential projects should be currently excluded with the intention of creating a less burdensome requirement for residential projects in the future