Regulator Provides Guidance On RPS, Given Recent Changes

The Connecticut PURA issued a notice of proceeding concerning retail supplier and EDC compliance with the RPS for 2019 (Docket 20-06-01) that includes guidance given recent changes in compliance regulations

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 2019 RPS compliance filings, including the Q5 allowance," PURA said

"Accordingly, for the 2019 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 2020 RECs for 2019 RPS compliance," PURA said

"However, pursuant to the declaratory ruling issued in Docket No. 19-10-40, the fifth quarter will discontinue after the 2019 compliance year. Docket No. 19-10-40, Declaratory Ruling Regarding Renewable Portfolio Standards Fifth Quarter, Declaratory Ruling, p. 4," PURA said

PURA further said that, after July 31, 2020, it will no longer entertain any requests for Authority approval to reallocate and use misplaced or inadvertently transferred RECs

"Any motions regarding misplaced or inadvertently transferred RECs in the NEPOOL-GIS system must be filed with the Authority no later than 12:00 P.M., July 31, 2020," PURA said

"After July 31, 2020, the Authority will no longer entertain any requests for Authority approval to reallocate and use misplaced or inadvertently transferred RECs for the 2019 RPS compliance year, and any subsequent compliance years thereafter. After July 31, 2020, load serving entities will be solely responsible for properly managing, transferring and settling their RECs in the NEPOOL GIS system," PURA said

The Connecticut Light and Power Company and The United Illuminating Company (together EDCs) are required to submit, by noon on September 15, 2019, Final Settlement Load information for all load-serving entities for the year 2019. All electric suppliers are required to use The Connecticut Light and Power Company’s and The United Illuminating Company’s Final Settlement Load information to determine any RPS or ACP obligations, which shall be filed with the Authority on the prescribed, "Annual Connecticut Renewable Portfolio Standards (RPS) Filing" form.