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DE 13-216, David Gould's, Inc.'s Request for Recognition of Class II Renewable Energy Certificates (RECs) Intended for Banking in June, July, August...

July 22, 2014



DE 13-216, David Gould's, Inc.'s Request for Recognition of Class II Renewable Energy Certificates (RECs) Intended for Banking in June, July, August and September 2013

CONCORD, N.H., July 22 -- The New Hampshire Public Utilities Commission issued the following Secretarial Letter:

Re: DE 13-216, David Gould's, Inc.'s Request for Recognition of Class II Renewable Energy Certificates (RECs) Intended for Banking in June, July, August and September 2013

Dear Mr. Gould:

On July 16, 2014, the Commission received a hardcopy of your e-mail requesting that the Commission approve reinstatement of 13 renewable energy certificates (RECs) generated during 2013 by your residential solar photovoltaic array (PV), so that these RECs can be transferred and banked to meet future renewable portfolio standard (RPS) compliance obligations. You own and operate a PV facility named "Pennacook," which is located at 81 Hall's Mill Road in Candia, New Hampshire (Gould-Pennacook). The Commission approved the Gould-Pennacook PV facility as a Class II renewable energy source, effective as of July 25, 2013. The New Hampshire certification for the Gould-Pennacook facility is NH-II-13-081, and the NEPOOL GIS facility code is N0N37975.

In your filing, you maintained that you were unaware of the applicable NEPOOL-GIS trading deadlines, due to relative inexperience with the REC markets, and as a result you failed to act prior to these deadlines to transfer ownership of the 13 RECs generated by the Gould Pennacook PV facility during the second and third calendar quarters of2013.1 This failure resulted in the retirement of these RECs towards the Residual Mix.2

To resolve this discrepancy, the Commission has the authority to approve reinstatement of eligible Class II RECs back into the Gould-Pennacook account. This action would effectively permit the RECs in question to be transferred and banked to meet future RPS compliance obligations.

Based on information provided to Commission Staff by the NEPOOL-GIS administrator, the following table summarizes the status of the 13 RECs in question:

Click here to view table (http://www.puc.state.nh.us/Regulatory/Secretarial%20Letters/072214slDE13-216%20David%20Gould.PDF)

Staff has recommended that the Commission approve reinstatement of the seven Class II RECs generated by the Gould-Pennacook PV facility during August and September 2013. Because the GIS certificates created with respect to June and July 2013 are ineligible for Class II as they relate to electricity generated prior to the date of the Commission's eligibility certification, Staff recommended that the Commission deny reinstatement of these six RECs.

The Commission has reviewed your request'and Staffs recommendation, and has detennined it is consistent with its statutory authority and NEPOOL-GIS rules to reinstate the seven RECs created with respect to Gould-Pennacook generation during August and September 2013. The Commission will recognize and accept these reinstated RECs for future RPS compliance, provided that the electricity provider claiming them for compliance has submitted the following documentation:

1. Your notarized statement attesting that the NEPOOL-GIS certificates listed in the statement have not otherwise been, nor will be, sold, retired, claimed, used, or represented as part of electrical energy output or sales, or used to satisfy obligations, in any jurisdiction(s) other than New Hampshire;

2. A copy of this Commission secretarial letter approving reinstatement of the seven Class II RECs; and

3. An amended E-2500 Report filed by the provider for the 2013 RPS compliance year listing the seven Class II RECs as banked for future use, which amended Report has been accepted by the Commission. This decision regarding the aforementioned NEPOOL-GIS certificates shall not be regarded as establishing a precedent, and the Commission may deny any similar requests for reinstatement or waiver in the future. A copy of this letter is being sent to the NEPOOL-GIS administrator.

Sincerely, --

Debra A. Howland

Executive Director

cc: James Webb, Registry Administrator, APX Environmental Markets

CC AutoTriage15db-140724-30VitinMar-4807489


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