For customers looking to register systems in the DC SREC market, as we have previously stated, DC will accept applications from customers sited in the PJM regions and states adjacent to the PJM region where electricity is eligible to be transmitted into the PJM region. SRECTRADE will manage the application process for our EasyREC customers to ensure the system is approved.
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.