DC Facility Rejections
We previously reported that a facility was rejected out of New York state and have learned that the application provided that the electricity was not capable of being transmitted into the PJM region. The DC PSC was subsequently unable to get clarification in order to approve the facility.

A second facility in New York has also been rejected because there was “no basis to conclude that the facility generates electricity consumed within the PJM Interconnection region.”  We are currently seeking clarity on how these determinations are made and will post them when we have more information.  In the meantime, here are some details:

DC rule 945-E-1764 (http://www.dcpsc.org/pdf_files/commorders/dcmr15/Chapter29.pdf) defines a renewable energy credit as “a credit representing one megawatt hour of electricity consumed within the PJM interconnection region that is derived from a tier 1 renewable source, a tier 2 renewable source, or a solar source that is located:

“In the PJM Interconnection region or in a state that is adjacent to the PJM Interconnection region.”

The same document describes New York as an “Adjacent PJM State” and the New York Independent System Operator (NYISO) as an “Adjacent Control Area”.  The crux of the issue seems to be the wording “consumed within the PJM interconnection region”.  Electricity flows bidirectionally between PJM and NYISO every day, the amount varying based on supply and demand in the two ISOs.  An electron generated in NYISO clearly can’t be tracked (Heisenberg and all), so there is no way to know if a given electron generated by the grid-tied solar installation makes its way into PJM and is consumed. In fact there is no way to know if a given electron generated by any installation in any “Adjacent PJM State” makes its way to PJM and is consumed there, although it is possible that any electron generated in an adjacent PJM state will. Going even further, an electron generated by a system located in DC might actually be consumed outside PJM! As we see it, this leaves two choices on how to interpret the DC RPS rules. Either every grid tied generator in an “Adjacent PJM State” could be delivering their electrons to be consumed in PJM and therefore all are eligible to create DC renewable energy credits, or none can prove that their specific electrons where consumed in PJM and so none are eligible.

How far back will DC accept SREC generation?
We also get questions about systems that were installed prior to the application date in DC. Customers and installers will ask how far back DC will count solar generation for SRECs. DC will only count SRECs created in the current energy year (same as calendar year) as long as generation is inputted before the last business day in January. This means that, as of this blog post, any generation for a facility in 2009 will not count. Only generation from January 2010 onwards will be eligible for the creation of SRECs.

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In Pennsylvania, for example, a resident within the PJM region can apply for certification in the Pennsylvania SREC program.  If your system is convered in this map, you can sell SRECs to PA!

Washington, DC is similar to Pennsylvania in that both allow SRECs from anywhere within the PJM region, however DC will also qualify facilities that are eligible to deliver their electricity into the region. This may include facilities in states that are adjacent to the PJM region such as New York or Wisconsin.

Ohio is another state that allows SRECs from out of state. In that specific case, the utilities are limited to buying 50% from out of state and only from states within the region that are contiguous: Pennsylvania, West Virginia, Kentucky, Michigan and Indiana.

Washington, DC is similar to Pennsylvania in that both allow SRECs from anywhere within the PJM region, however DC will also qualify facilities that are eligible to deliver their electricity into the region.

For these reasons, it is important to know what constitutes the PJM region to determine whether or not you qualify.  Here is a map of the region, along with the retail electricity companies who are served by PJM.

We are working with the DC Public Service Commission to get clarity on how to determine whether facilities sited in states adjacent to the PJM Region are indeed eligible for the DC SREC program and will provide an update as soon as possible.

The DC Public Service Commission is responsible for approving applications to the DC SREC market.  Their rule of thumb is that if your state has an RPS similar to DC you are guaranteed certification in DC. Currently those states include Maryland, Pennsylvania, Delaware, New Jersey and Ohio.

Solar facilities built in all other PJM area states AND adjacent states are reviewed closely and the DC PSC will determine if they can be granted certification. Currently, they have not declined a registration from any of those states because of location. Based on the map of the PJM region, these states include: Indiana, Illinois, Kentucky, Michigan, Tennessee, Virginia, West Virginia and Wisconsin.

Here is a link to get you started:

DC Certification Instructions

Registering in Ohio

Utilities in Ohio are allowed to procure 50% of the SRECs from out of state facilities. However, these states must be contiguous with Ohio (PA, MI, IN, KY, WV). Instructions and forms required for Ohio certification can be found here: Application for Certification as an Ohio Renewable Energy Resource Generating Facility

Contact:
Public Utilities Commission of Ohio
Email: AEPS@puc.state.oh.us
Toll-Free: (800) 686-PUCO (7826)
Phone: (614) 466-3292 (in Columbus area)
Fax: (614) 752-8351
180 East Broad Street
Columbus, Ohio 43215
Directions to the PUCO

Delaware
Illinois
Indiana
Kentucky
Maryland
New Jersey
New York
North Carolina
Pennsylvania
Tennessee
Virginia
West Virginia
Wisconsin

Check our DC State Eligibility post for more information. For detailed instructions on how to apply, go to the DC Certification Blog Post.