Regulator Issues Guidance For Retail Suppliers On RPS Compliance, Given Statutory Changes
September 24, 2019 Email This Story Copyright 2010-19 EnergyChoiceMatters.com
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The Connecticut PURA issued guidance to retail electric suppliers concerning RPS compliance and opened Docket 19-06-01 to review and determine the electric suppliers’ and electric distribution companies’ (EDCs) compliance with the Connecticut renewable portfolio standards (RPS) in the year 2018.
PURA noted that Public Act 17-186, An Act Concerning Renewable Portfolio Standard Compliance Requirements, amended Conn. Gen. Stat. § 16-245a by eliminating the provisions that allowed load-serving entities to make up a deficiency in an annual renewable portfolio standard (RPS) obligation in the first three months of the following calendar year (commonly referred to as 'the Q5 allowance').
"Since load-serving entities may have already taken actions based upon reliance on the former version of Conn. Gen. Stat. § 16-245a(e) and previous guidance by the Authority, the Authority will maintain its current procedures for reviewing the 2018 RPS compliance filings, including the Q5 allowance. See, October 9, 2018 Revised Notice of Proceeding in Docket No. 18-06-28. Accordingly, for the 2018 RPS compliance year: (a) the annual RPS filings will be due October 15, 2019; (b) the Authority will use the Final Settlement Load (Post-90-Day) to determine a company’s total load and obligations; and (c) the companies will be allowed to use Q1 2019 RECs for 2018 RPS compliance," PURA said
"The Authority intends to amend its regulations to conform to the statutory requirements and modify any other requirements, if deemed necessary. While the regulation amendment process is underway, the Authority will provide procedural guidance in a separate Docket with respect to the requirements for the 2019 RPS compliance filings and beyond, after providing the opportunity for stakeholder comment," PURA said
"Pursuant to Conn. Gen. Stat. §§16-244c(h)(1) and 16-245(k), as amended by Public Act 17-144, An Act Promoting the Use of Fuel Cells for Electric Distribution System Benefits and Reliability and Amending Various Energy-Related Programs and Requirements, the Authority requires an alternative compliance payment (ACP) if a licensee fails to comply with the RPS. For calendar years commencing on and after January 1, 2018, Public Act 17-144 has reduced the ACP for Class II renewable energy sources from five and one-half cents per kilowatt hour to two and one-half cents per kilowatt hour," PURA said
Based on the foregoing, each electric supplier and EDC is required to file its 2018 RPS Compliance Report in this docket by no later than October 15, 2019. To demonstrate RPS compliance, each company is required to file the following documents:
1. Exhibit A (Annual CT RPS Filing);
2. Exhibit B (Class I and II RECs by Generator Location);
3. Exhibit C (Class I, II & III Fuel Sources);
4. Exhibit D (Voluntary Green Offerings);
5. Supporting GIS documentation (copies of “My Settled Certificates” Reports) showing RECs used (settled) for Connecticut RPS compliance; and
6. Name, address, email address and phone number of company’s contact person for RPS compliance.
The exhibits for the annual RPS compliance filing are available at the Authority's website
Additionally, The Connecticut Light and Power Company and The United Illuminating Company are required to submit, by September 16, 2019, Final Settlement Load information for all load-serving entities for the year 2018.