Public ServiceCommission
of the
District of Columbia
Report on the RenewableEnergy Portfolio Standard for ComplianceYear 2015
May 2,2016 TABLE OF CONTENTS
E)(ECUTTVESI.JMMARY ...... i
L Introduction and Background I
II. Summaryof the lmplementationof the RenewableEnergy Portfolio Standard...... 3 RPSRules. ...4 ComplianceRequirernentsfor Electricity Suppliers ...... 4 Certificationof RenewableGenerators...... 5 Creationand Trackingof RenewableEnergt Credi* ...... 7 Recoveryof Feesand Costs...... 8 Cleanand Affordable Enerw Act of 2008 ...... 8 DistributedGe,neration Amendment Act of 201I ...... 10 RenewableEnerey Portfolio StandardAmendment Act of 2014 ...... l3 m. RPSCompliance Reports for 2015...... 15
IV. The Availability of RenewableResources ...... 20
V. Rece,ntActivity andNext Steps...... 26
Attachme,ntl: RenewablePortfolio Standards in OtherStates...... 28
Attachmeirt 2: Selected Commission Orders and Notices on the Implementation of the RenewableEnergy Portfolio Standard...... 33
Attacbme,nt3: Map of the Certified Solar Energy Systemsinthe District of Columbia...... 4l EXECUTIVE SUMMARY
The RenewableEnergy Portfolio StandardAct ("REPS Act") requires the Public Service Commissionof the District of Columbia ("Commission") to annually re,portto the Council of the District of Columbia on the status of implementation of the Renewable Portfolio Standards("RPS";, including the number of renewablegenerators approved by the Commission and eligible to participate in the District's RPS program; the availability of renewableresources; and the certification of the number of credits generatedby the utilities meeting the requirementsof D.C. Offrcial Code 5 34-1432, which outlines the minimum percentagesto be derived from certainrenewable resources-and any other such information as the Council shall considernecessary. This annualreport fulfills the reporting requirement outlined in the REPSAct for the most recentcompliance year of 2015.
Pursuantto the Commission's RPS rules, 33 active electricity suppliers with retail electricity salesin the District submittedcompliance reports due on April l, 2016 reportingon their RPS compliancein 2015. Thesereports show that electricity suppliersgenerally met the RPS requirementsthrough purchasing renewable energy credits ("RECs") and making compliance payments. Eighteen electricity suppliers submitted a compliance payment representingin most casesa portion of their complianceobligation. The compliancefees are deposited into the Renewable Energy Development Fund which is administered by the Disffict's Department of Energy and Environment ("DOEE"). The total amount of compliancepayments for 2015was $19,910,000,compared to $6,308,710in feesgenerated in 2014,-an increaseof more than three times the $6.3 million paid for in the 20L4 reporting year. Although the reportedretail salesdid not changesignificantly, the salessubject to the higher solar requirements under the Distributed Generation Amendment Act ("DGAA") of 20ll was 99.2 percentin 2015 comparedto 82.2 percent :rr.2014. In addition, the available capacityfrom solar energysystems certified for the District's RPS program is well below the required capacity,resulting in a shortageof qualifoing solar RECS. Other things the same, this shortageof solar capacitywill only increaseas the solar requirementcontinues to rise over time.
As of December 31, 2015, there were 4,407 renewablegenerators approved by the Commissionand eligibleto participatein the District's RPS program. As of April 19,2016, there are 4,545 renewablegenerators approved by the Commissionand eligible to participate in the District's RPS program. Of the facilities approved,4,516 (99.4 percent)use Tier I resources(including biomass,methane from landfill gas,solar, and wind) and29 (0.6 percent) use Tier II resowces(i.e., hydroelectric). Since theserenewable generators may be certified in other statesthat have a RPS requirernentas well, the renewableenergy credits associated with the generatingcapacity are not necessarilyfully availableto meetthe District'sRPS.
There are currently 4,395 solar energysystems (including both solar photovoltaicand solar thermal) eligible to meet the District's solar RPS requirement,of which 2,124 are locatedwithin the District. The 2,124 District RPS-eligiblesolar energysystems are located in all 8 wards in the following numbers:ward | - 265; ward 2 - 108;ward 3 -346;ward 4 :338; Ward 5 -271, Ward 6 - 381; Ward 7 -263; and Ward 8 - 152.t Outsideof the District, there are six stateswith more than 100 RPS-eligiblesolar energy systemsincluding Pennsylvania(929), Virginia (493), Maryland (221), North Carolina (156), Delaware(150), and Ohio (132). These six (6) statesaccount for roug$y 92 percentof the non-DC solar energy systemsapproved for the District's RPS program. There are also RPS-eligiblesolar energysystems in eight additionalstates.
As a result of the adoption of the DGAA,2 which required all solar photovoltaic and solarthermal facilities certified by the Commissionafter January31,2011 to be locatedin the District or on a distribution feeder serving the District, the District had seen a significant decreasein the numberof solar generatorapplications for the RPSprogram. In particular,the number of applications,primarily solar, increasedfrom 461 in 2009 to 2,034 in 2010, before falling to 1,846in 2011,and 257 n 2012. However,since 2013, the decliningtrend has been reversed.The RPS applicationsincreased to 391 lr;,2013,473n2014, and7l7 in 2015. As of April 15,2016,the Commissionhas received 146 applications in 2016.
The total reportedcapacity associated with the approved4,395 solar energysystems as of April 19,2016 is about 39.6 megawatts("MW'). About 19.2 MW of this capacityis located in the District. The current reported solar capacity is up from 38.8 MW of solar capacityas of December31,2015. Currently,the capacityindicated in the District is roughly in parity with the out-of-statesolar capacity that was grandfatheredinto the RPS program. This is generallyconsistent with the decreasein the retirementof out-of-statesolar RECs for the 2015 complianceyear; specifically in the 2015 complianceyear, only 56.1 percentof the RECs were from out-of-statesystems, compared to nearly 7l percentout-of-state solar RECs ' retired in the 2014 complianceyear.
While the amount of DC-basedcapacity is still increasing,it is still well below the solarcapacity that is necessaryto meet the solar RPS requirementof the DGAA. That needis an estimated59.0 MW for 2015 to meet the required0.70 percentof all District of Columbia retail electricity sales and 69.9MW in 2016 to meet the required0.825 percentof all District of Columbia retail electricity sales. The enactmentof the Community RenewableEnergy Act and of legislation lifting the 5 MW cap on the size of solar installationsowned by District agenciesthat are eligible for certification have the potential to acceleratethe number of DC- basedsolar RECs that may be availableto suppliersfor compliancepurposes in the upcoming years.
On the other hand, the amount of electricity supply sold by retailers in the District that is exempt from compliancewith the increasedrequirements of the DGAA is also declining significantly. The DGAA included a "grandfathering" provision that exempts electricity
' SeeAttachment 3.
2 D.C. Act 19-126 (August l, 2011). The permanent version of this legislation, the Distributed GenerationAmendment Act of 201l, becamelaw on October20,2011. SeeD.C.Law 19-0036.
3 A REC representsone megawatt-hourof electricity generation,attributable to a particularrenewable energysource. supply contractsthat were executedprior to the effective date of the legislation (August 1, 20ll), from the higher RPS requirement. As multi-year contacts have expired, the percentageof such exemptsales has decreasedfrom 96 percentin 2011 to 71 percent n2012 to 37 percentin 2013and then about l8 percentn2014. ln 2015,roughly 0.8 percentof sales were r€,portedas exempt from the DGAA requirement.
For the 2016 complianceyear, the estimatedsolar capacityneeded to meet the RPS solar requirernentof 0.825 percent of sales is about 70 MW. As of April 19, 2016, the Commissionhas certified only about 39.6 Mw-including the out-of-statesystems that were grandfatheredinto the program. Thus, compliancecosts will most likely continueto rise over time.a
The Commission tracks the number of renewable energy credits submitted for compliance. A breakdown of the number of RECs for 2015, submitted by fuel type, is provided in the table below:
RenewableEnergy Credits Submitted fior 2015 Compliance
No. of REGs Share of Tier Tier I Resource BlackLiquor 301,405 26.5o/o Itletranefrom landfill C'as 109.724 9.60/o Wind 225,40 19.8o/o Wood Waste 4,/}5,786 39.2Yo l,lon-SolarTier | (out-of-stiatesolar) 17.918 1.60/0 Solar 38.167 3.4o/a TotralTierI 1.138.480 100.0% Tierll Resource F{ydroelectic 220,528 100.0% MunicipalSolidWaste 0.0o/o TotalTierI and ll 1.359.008
The Commissionaddressed the changesthat were adoptedby the Council in the Fiscal Year 2015 Budget SupportAct of 2014 in a Notice of Final Rulemaking('NOFR') that appearedin the D.C. Register on October 30,2015. This Act amendedthe RPS statutesto allow solar energy systems larger than 5 MW in capacity located on property owned by the District, or by any agency or independentauthority of the District, to meet the solar requirement. It also clarified that solar facilities locatedin PJM or in a stateadjoining PJM may be certified by the Commissionand their RECS may be usedby electricity suppliersto meet the Tier I renewable resourcerequirement that falls outside of the DC-based solar requirement.
The Commission also addressedthe changesto the eligibility of biomass facilities pursuantto the RenewableEnergt Portfolio StandardAmendment Act of 2014, passedby the
lll Council on December 17,2014, in a NOFR that appearedin the D.C. Register on April I, 2}l6.s Among other things, this legislation impacted the eligibilrty of RECs retired from biomass facilities for the 2015 reporting year. Tho Commission addressedthe matter with the electricity suppliers by contacting suppliers to confirm if they were in compliance and, if appropriate,requesting that alte,mativeRECs be submitted to e,nsurecompliance with the RPS require,ments. In addition, this legislation has the effect of reclassiffing a majority of the biomass (including black liquor) facilities as Tier II resources, because they began commercial operation on or before Dece,mber31,2006. The Commission is in the processof changing the certification statusof thesebiomass facilities.
t RcnewableEnerry Portfolio StandardAne,ndment Act of 2014,cffective April 30, 2015(D.C. Laut 20- 245;62DCR1492 (February 6,2015)))
lv I. Introduction and Background
The Council of the District of Columbia ("Council") enactedthe RenewableEnergy Portfolio StandardAct ("REPS Act") on January19,2005 and establisheda renewableenergy portfolio standard ("RPS"), through which a minimum percentageof District electric providers' supply must be derived from renewableenergy resourcesbeginning January l, 2007. The RPS minimum requirements,among other things, were amendedby the Clean and Affordable EnergyAct ("CAEA") of 2008.o Furtherchanges to the RPSprogram occurred on August I,2011, when the DistributedGeneration Emergency Amendment Act of 2011 ("DGAA") becamelaw.7 Additional amendmentsto the RPS program becameeffective on April 30, 2015, as a result of the RenewableEnergy Portfolio StandardAmendment Act ("REPS AmendmentAct") of 2014.
Renewableenergy resourcesare divided into trvo categories,Tier I and Tier II, with Tier I resourcesincluding solar energy,wind, biomass,methane, geothermal, ocean, and fuel cells, and Tier II resources including hydroelectric power other than pumped storage generationand waste-to-energy.oAlthough minimum percentagerequirements are specified for Tier I and Tier II resources,Tier I resourcescan be used to comply with the Tier II standard.In addition,a minimum requirementis carvedout specifically for solar energy. The REPS Act allows an electricity supplier to begin receiving and accumulatingrenewable energycredits as ofJanuary 1,2006.
The REPS Act required that the Public Service Commission of the District of Columbia("Commission") adopt regulations, or orders,governing the applicationand transfer of renewableenergy credits and implementationof the REPS Act. The RPS rules became effective upon the publication of the Notice of Final Rulemaking in the D.C. Register on January18, 2008. The Commission'sRules can be found in Chapter29 of 15 DCMR. As part of its RPS rules, the Commissionestablished a processfor certifying eligible generators. The certification processincludes a streamlinedapplication that the Commissiondeveloped. Renewable generators do not need to submit as much documentation for the streamlined applicationand the Commissionis requiredto take action in a shorterperiod of time.
On October22,2008, the permanentversion of the Clean and Affordable Energy Act of 2008 ("CAEA") becamelaw. The law, among other things, amendedthe REPS Act and changedthe definition of solar energyto provide eligibility for solar thermal applicationsthat do not generateelectricity, raisedthe RPS requirementsto 20 percentby 2020,and increased certainalternative compliance fees.
o D.C. Official Code g 34-1432(c)(2012 Supp.). 7 D.C. Act 19-126 (August 1, 20ll). The permanent version of this legislation, the Distributed GenerationAmendment Act of 2011, becamelaw on October 20,2}ll. See D.C. Law 19-0036. Since emergencyand permanentversions of the legislationare identical, both are referredto as the DGAA.
-AsofJanuary l,20l3,theincinerationofsolidwasteisnolongereligibletogeneraterenewableenergy credits for the District's RPS program. On August I,2011, the Distributed GenerationEmergency Amendment Act of 20l l ("DGAA") became law.e The DGAA disallowed most new solar energy systemslocated outside of the District from being certified by the Commission for the RPS program, after January 3I, zOll-although solar energy systemslocated outside of the District that were certifred prior to February 1,201I were "grandfathered"and remain eligible under the RPS program. In addition,among other things,the legislationincreased the solar RPS requirement from 2011 through 2023 (up to 2.5 percent by 2023 as opposedto 0.4 percent by 2020), disallowed the certification of solar energy systemslarger than 5 megawatts("MW") in capacity, amended the solar compliance fees for 2011 throudh 2023, and changed the eligibility requirementsfor solarthermal systems.
Pursuantto the DGAA, in Order No. 16528(September 9,2011), the Commission denied all applicationsof solar energy facilities seeking certification as eligible District of Columbia renewableenergy standards generating facilities, which were not locatedwithin the District, nor in locations servedby a distribution feeder serving the District, and pending before the Commissionon August l,20ll. Moreover,in Order No. 16529(September 9, 20lI), the Commissiondecertifred 1,426 solar energyfacilities not locatedwithin the District, or in locations served by a distribution feeder serving the District, and certified by the Commissionbetween February l, 2011, and the effective date of the Act, August l, 2011, as well as any solar facilities with a capacitylarger than 5 MW, regardlessof the datecertified.
As a result of the REPS Amendment Act of 2014, the eligibility of "qualifying biomass"resources was changed.The legislationrequires that, to qualify as a Tier I resource, a generationunit using biomassmust achievea total systemefficiency of at least sixty-five (65) percent on an annualbasis, demonstratethat it achieveda total systemefficiency of at least 65 percent on an annual basis through actual operational data after one year, and demonstratethat it stanedcommercial operation after January1,2007 and refrain from using black liquor. Under this law, those biomass generationunits that cannot achieve a total systemefficiency of at least 65 percent,or that startedcommercial operations on or before December 31, 2006, or that use black liquor, can no longer qualifu as Tier I resources. Rather, they now qualify as Tier II resources. Finally, any extensionor renewal of energy supply contractsexecuted on or after August 1,2011 shall be subjectto the higher solar energy requirement.
ln calendar year 2015 there were 33 electricity suppliers, including the default StandardOffer Service Provider, who reported electricity sales to retail customersin the District. Pursuantto the Commission'sRPS rules, each of theseactive electricity suppliers submitted the required compliance report that was due by the then applicable deadline of April l, 2016. These reports show that electricity suppliers generally met the RPS requirementsthrough purchasingrenewable energy credits ("RECs") and making compliance payments. Eighteen electricity suppliers submitted a compliancepayment in lieu of (or in
' D.C. Act 19-126 (August l, 20Ll). The permanent version of this legislation, the Distributed GenerationAmendment Act of 2011.became law on October20.2011. SeeD.C.Law 19-0036. addition to) acquiring RECs.r0 Based on the available information, the total amount of money ganerated from compliance payments in 2015 was $19,910,000 In Section II, we provide a summaryof the stepsthat the Commissionhas taken to implementthe RPS in the Dishict. SectionIII reviews the RPS compliancereports submitted for the 2015 complianceyear. In Section IV, we present some information on the current availability of renewableresources. Finally, SectionV summarizesother ongoing actionsto implement the RPS in the District and next steps. In addition, we include Affachment 1, which provides a national perspectiveon what other states are doing with respect to the implementationof their renewableportfolio standards.ll Attachment 2 contains a list of selectedorders that the Commissionhas issuedto implementthe RPS. Lastly, Attachment3 includesa map of the certified solar energysystems in the District of Columbia.12 II. Summary of the Implementation of the RenewableEnergy Portfolio Standard This sectionprovides a brief descriptionof the history of actionsthat the Commission has undertaken to implement the RPS.I3 In order to establish a record and to begin implementationof the REPSAct, the Commissionissued Order No. 13566on April 29,2005, inviting interestedparties to submit their views on twelve (12) RPS-relatedissues. The twelve issuesaddressed: a the processand timeline that the Commissionshould adopt to implementthe Act; o the procedureto apply for, veriff, and transfer renewableenergy credits; a the type(s)of renewableenergy projects that are feasiblewithin the District; a the processfor certiffing the eligibility of generatingfacilities; a the standardsthat should apply to customer generators; a the information that shouldbe submittedin an electricity supplier'sannual compliance report; the appropriateprocedures for costrecovery by Pepco; to The compliance fee payments are deposited into the Renewable Energy Development Fund administeredby the District Deparfinentof the Environment("DDOE"). rr Statessuch as Connecticut,Hawaii, Michigan, Nevada,North Carolina,Ohio, and Pennsylvaniainclude energyefficiency in their RPS. t2 The map was produced by Commission staff using the data maintained for the RPS generator certification. 13 Attachment 2 of this Report containsa list of selectedCommission Orders and Notices addressingthe implementationof the RPS program. o the standards that the Commission should ernploy for determining whether the compliancecosts claimed by Pepcowere prudentlyincurred; o the verificationof an electricitysupplier's compliance with the RPS; o the imposition of an administative fee; o the dataand confidentialityconcerns ofstakeholders; and o the statesthat qualify as being within or adjacentto the PJM InterconnectionRegion. In Order No. 13766,released on September23,2005, the Commissionaddressed the various issuesbased on the record developedin responseto Order No. 13566. Among other things, the Commission directed interestedparties to form a RPS Working Group to examine in more detail certain issuesrelated to the implementationof the REPSAct, and to proposea timeline and recommendationsfor a two-phasedapproach to resolving those issues.la The Commission also indicated that the PJM EnvironmentalInformation Services("PJM-EIS") GenerationAttribute Tracking System("GATS") would be usedin the implementationof the Act. In addition, the Commissionindicated its intent to establishregulations to govern the applicationand transferof RECs,on an interim basis,prior to January1,2006. RPS Rules Based on input from the RPS Working Group, the Commission establishedinterim RPSrules in OrderNo. 13840(December 28,2005). Theserules were subsequentlyamended in Order No. 13899 (March 27, 2006) and Order No. 14225 (March 2, 2007). The Commissioneventually established a formal rulemakingprocess and on November2,2007, a Notice of Proposed Rulemaking ("NOPR") appeared in the D.C. Register requesting commentson revised RPS rules that were based,io purt, on the interim RPS rules. After receiving and reviewing commentson the NOPR, the Commissionissued Order No. 14697 (January 10, 2008) and adopted Chapter 29 of Title 15 District of Columbia Municipal Regulations("Final Rules"). The Final Rules becameeffective upon the publication of the Notice of Final Rulemaking("NOFR") in the D.C. Registeron January18,2008. The rules establish definitions for various terms consistent with the REPS Act, compliance requirements for elechicity suppliers, certification of renewable generators, policies regardingthe creationand tracking of RECs, and directivesconcerning the recovery offees andcosts. Compliance Requirementsfor Electricity Suppliers The RPS rules include compliancerequirements for electricity suppliersbeginning in 2007. Under the current requirements, suppliers are to file annual reports that include the following components: (l) the quantity of annual District retail electricity sales; (2) a calculationof the annualquantity of requiredTier I, Tier II, and Solar EnergyCredits; (3) the quantity of Tier I, Tier II, and Solar Energy Credits purchasedand evidence of those purchases;(4) the quantity of Tier I, Tier II, and Solar Energy Credits transferredto the t4 In AttachmentA of Order No. 13766,the RPS Working Group was askedto address23 issues. electricity supplier by a RenewableOn-Site Generator;(5) a calculation of any compliance fees owed by the energysupplier; (6) certification of the accuracyand veracity of the report; (7) all documentationsupporting the data in the annual compliancereport; (8) a list of all RECS used to comply with the RPS; (9) a sunmary report of RECs retired during the reporting period; and (10) the total price paid for Tier I, Tier II, and Solar Energy Credits. Suppliers that purchaseRECs solely via bundled products are exempt from including the total price paid for Tier I, Tier II, and Solar Energy Credits in their annualcompliance report. The Commission allows the information in item (10) to be filed confidentially. An electricity supplierthat fails to meet its RPS requirementsmust submit an annualCompliance Fee to the District of Columbia RenewableEnergy Development Fund administeredby the District Departmentof the Environment'sEnergy Office ("DDOE") by April 1 of the calendaryear following the yearof compliance. To facilitate the compliancereporting, the Commission issuedOrder No. 14782 on April 10, 2008 and adopteda2007 ComplianceReport form for the District's RPS Program, along with the associatedfiling instructions. This material was made available on the Commission'swebsite. Electricity suppliersused the form to submit the 2007 compliance reportsdue May 1, 2008. A revisedcompliance reporting form was included in a January2, 2009 NOPR, to reflect changesmandated by the CAEA. The revised compliancereporting form was adoptedin Order No. 15233(April 7, 2009) and becameeffective upon publication of the NOFR in the D.C. Register on April 10, 2009. The compliancereporting form was revised again in order to addressthe DGAA legislation,with a NOPR appearingin the D.C. Registeron January13, 2012. The revisedcompliance reporting form was adoptedin Order No. 16738(March L5, 2012) and becameeffective upon publicationof the NOFR in the D. C. Registeron March 23,2012. CertiJication of Renewable Generators The RPS rules outline the processfor certifying renewablegenerating facilities within a certain period of time. Renewable generators,including behind-the-meter("BTM") generators,must be certified as a qualified Tier I (including solar energy systems)or Tier II resotucethrough the completion of an application form approvedby the Commission.ls In situationswhere the applicanthas obtainedcertification as a renewableenergy resourceby another PJM state where the Commission determinescertification to be comparableto the RPS requirementsin the District, the applicantmay submit a "streamlined"application that requires less documentationto be filed. The Commission assignsa unique certification number to each eligible renewable generatorthat is approved. Renewablegenerators may be decertifiedby the Commissionif they are determinedto no longer be an eligible renewable resourcedue to a material change in the nature of the resource,or fraud. Before being decertified, a renewable generatorwill be given thirty (30) days' written notice and an opportunityto show causewhy it shouldnot be decertified. 't A behind-the-metergenerator is defined as a renewableon-site generatorthat is locatedbehind a retail customermeter such that no utility-owned transmissionor distribution facilities are used to deliver the energy from the generatingunit to the on-sitegenerator's load. In Order No. 14809,issued May 12,2008, the Commissiondirected the Renewable Energy Portfolio StandardWorking Group ("Working Group") to submit an update for the Tier I and Tier II eligibility matrices,in order to comply with the RPS rules. The matrices allow an applicantthat has alreadybeen certified by anotherPJM stateto use the streamlined processfor certification,provided that the Commissiondetermines that the certificationby the other PJM state is comparableto the RPS requirementsin the District. The RPS Working Group respondedon October 31, 2008 that no update was required. Subsequently,the Commission issued Order No. 15192 on February 18, 2009, directing the RPS Working Group to againcomply with the rules and submit an updatefor the Tier I and Tier II eligibility matriceswithin 60 days of the date of the Order. The Commissionnoted in that Order that since2007, four (4) additionalstates that arepart of the PJM Interconnectionregion-Illinois, Michigan, North Carolina, and Ohirhave adoptedrenewable energy portfolio standards and/or begun certifying renewableenergy generators. In Order No. 15707 (February 25, 2010), the Commissiongranted the PotomacElectric Power Company("Pepco"), filing on behalf of the RPS Working Group, a Motion for Enlargementof Time to file the annual update of the eligibility matrices by March l, 2010. Subsequently,in Order No. 17062 (February l, 2013), the Commission adopted the 201I filing of the RenewableEnergy Portfolio StandardWorking Group's proposedTier I and Tier II Eligibility Matriceswith certainmodifications.t6 On January 13,20!4, in Order No. 17349,the Commissionadopted the RPSWorking Group's proposedTier I and Tier II Eligibility Matricessubmitted for 2013. On January 30, 2014, the RPS Working Group's filing indicated that there were no modificationsneeded to the eligibility matricespresented in the 2013 Working Group report. Thus, no Commissionaction was necessaryas the Working Group's 2013 eligibility matrices were adoptedin Order No. 17349. Subsequently,on January29, 2015, the RPS Working Group filed its 2015 Update to the RenewableGenerator Eligibility Matrix and determined that the information submitted in the 2014 Report remains unchanged,so no Commission action*us n".ersary.tt On October 3, 2008, the Commissionpublished a NOPR in the D.C. Register that contained revisions to the RPS rules that would, among other things, allow an applicant seekingto certifu a renewablegenerator for the District's RPS program to provide a self- certified Affidavit of Environmental Compliance. This Affidavit helps provide documentationthat the renewablegenerating facility complies with all applicablestate and federalenvironmental requiranents. On January2,2009, the Commissionissued an amended NOPR that supersededthe October 3 NOPR. OPC filed commentson February 11,2009. Subsequently,in Order No. 15233(April 7,2009), the Commissionadopted the amendments to Chapter 29. The amendmentsto the RPS rules becameeffective upon publication of a NOFR in the D.C. Register on April 10, 2009. Subsequently,at the discretion of the 16 The RPS Working Group did not file a report in 2012. On January30, 2013, the RPS Working Group submitteda requestfor an extensionof time to file its annualreport for 2013. The RPS Working Group filed its 2013report on February28,2013. ti The RPS Working Group filed its report for 2016 on January 28,2016. The Commission is in the processof reviewing their filing. Commission, a NOFR appearedin the D.C. Register on January 16, 2015 to remove the application requirement for an Affidavit of Environmental Compliance from solar energy systemsthat exceedl0 kW. Creation and Tracking of RenewableEnergt Credits ('RECs) The RPS rules specify that RECs shall be createdand tracked through PJM-EIS's GenerationAthibute Tracking System ("GATS") beginning January 1,2006. Through the GATS process,PJM-EIS collectsgeneration data from facilities certified for RPSprograms in various states.Upon issuanceof a District-specific RPS certification number, a facility may open a GATS accountfor use with the District's RPS program. Facilities often are eligible for participationin severalstate RPS programsand, thus, will be certified with multiple states and receive multiple state certification numbers. GATS createsRECs at the end of each month. One REC representsone megawatt-hourof electricity from a renewableresource. The number of RECs createdreflects the amount of electricity generationassociated with renewable resources. Each REC tracked has a unique serial number that aids in ensuring againstthe double counting of RECs and helps distinguishbetween RECs that are createdby a certain facility and by fuel tlpe, in a given month. According to the RPS rules, RECs are valid for a three-yearperiod from the date of generationbeginning January 1,2006. A REC shall be retired after it is usedto comply with any state'sRPS requirement. The accumulationof retroactiveRECs createdbefore January 1, 2006 is not allowed. In Order No. 13804,the Commissionnoted that the intent of the REPS Act is to encouragethe production and siting of renewableresources prospectively, so as to reducethe needfor the use of retroactiveRECs. With respect to behind the meter ("BTM") generators,the RPS rules require an authorized representativeof the renewable on-site generator to file a BTM generator report with the Commission. RECs createdby BTM generatorsmust be recordedin GATS at least once each calendaryear, in order to be eligible for compliance. The BTM generatorreport contains, at a minimum, the following information: (a) a certification that the RECs attributableto the on-site generationhave not expired,been retired, been transferred,or been redeemed; and (b) a report or statement indicating the quantity of electricity generated as determinedby an engineeringestimate (if appropriate)or revenue-quality meter. To ensurethat all BTM generatorswere in compliancewith the Commission'srules, OrderNo. 14798(issued April29,2008) directedBTM generatorscertified for the District's RPSprogram to submit a BTM generationreport by May 20,2008. In addition, as part of the approval of 20 solar generators in Order No. 15185 (issued February 9, 2009), the Commission initially required that these generators provide BTM generation reports consistentwith the RPS rules. However, upon learning that PJM-EIS makes availableBTM generation information through its website, the Commission subsequently removed the reporting requirement for BTM generatorswhen the RPS rules were amendedby the NOFR that went into effect on March 23.2012. Recovery of Fees and Costs The RPS rules state that the local electric distribution company may recover prudently incurredRPS compliancecosts, including REC purchasesand any compliancefees, through a non-bypassablesurcharge on customers'bills pursuantto Commission rule 2904 and D.C. Code $ 34-1435(2014 Supp.) Pepco,as the StandardOffer Service("SOS") Administator, has never sought to recover RPS compliance costs for SOS through a non-blpassable surchargeon customers'bills. Instead,winning SOS suppliersbid a full requirementsproduct that includes all costs (including RPS costs)- other than transmissionand distribution costs which aretariffed costs. Like SOS suppliers,competitive electricity supplierssimply provide generationrather than breaking out the cost of generationinto line iterns such as RPS compliancecosts. RPS compliance costs are generally imbedded in the cost of generation charged by competitive electricity suppliers. Consistentwith Commission Rule 2904 and D.C. Code $ 34-1435, competitiveelectricity providers can also seekto recoverprudently incurred compliancefees through a Commission-approvednon-bypassable surcharge on customers'bills. To date, no electricitysupplier has ever sought or receivedthe Commission'sapproval to recoverthe cost of compliancefees. Clean and Affordable Enerev Act of 2008 On October 22, 2008, the permanent version of the CAEA became law. This legislation amendedthe REPS Act and the amendmentsare discussedbriefly below. The Commissionaddressed these amendments, as appropriate,in a NOPR issuedon April 3, 2009. After reviewing the commentsto the NOP& the Commissionadopted the NOFR in OrderNo. 15561 (September28,2009). The amendmentsto the RPS rules becameeffective upon publicationof theNOFR in the D.C. Registeron October2,2009. Solar Energt Deftnition The RPS Rules originally defined "solar energy" to mean "radiant energy, direct, diffirse, or reflected, received from the sun at wavelengths suitable for conversion into thermal,chemical, or electricalenergy''. The CAEA changedthe defrnition of "solar energy" to add the new languagein bold: "...radiant energy,direct, diffuse, or reflected,received from the sun at wavelengths suitablefor conversioninto thermal, chemical,or electrical energy,that is collected, generated,or stored for use at a later time." Solar System Ratings The CAEA allowed the certificationof solarthermal energysystems as follows: "For nonresidentialsolar heating,cooling, or processheat property systems producing or displacing greaterthan 10,000kilowatt hours per year, the solar systemsshall be rated and certified by the SRCC [Solar Rating and Certification Corporation] and the energy output shall be determined by an onsite energy meter that meets performance standardsestablished by OML [IntemationalOrganization of Legal Metrology]." "For nonresidentialsolar heating,cooling, or processheat property systemsproducing or displacing 10,000 or less than 10,000kilowatt hours per year, the solar systems shall be rated and certified by the SRCC and the energy output shall be determinedby the SRCC OG-300 annual system performance rating protocol applicable to the property,by the SRCC OG-100 solar collector rating protocol, or by an onsite energy meterthat meetsperformance standards established by OIML;" and "For residentialsolar thermal systems,the systemshall be certified by the SRCC and the energyoutput shall be determinedby the SRCC OG-300 annualrating protocol or by an onsiteenergy meter that meetsperformance standards established by OIML." RPSRequirements The CAEA amendedthe requirementsfor the RPS. In particular,beginning in 2011, the RPS requirementsincreased. By 2020, the CAEA requires that 20 percentof electricity supplied comes from Tier I renewableresources only and not less than 0.4 percent comes from solar energy. Previously, the RPS requirementcalled for 8.5 percent of electricity suppliedcoming from Tier I resourcesonly by 2020 and0.329percent from solar energy.18 SolarRequirement The CAEA required that: "...an electricitysupplier shall meet the solarrequirement by obtainingthe equivalent amount of renewable energy credits from solar energy systems interconnectedto the distribution grid serving the District of Columbia. Only after an electricity supplier exhausts all opportunity to meet this requirement that the solar energy systems be connected to the grid within the District of Columbia, can that supplier obtain renewableenergy credits from jurisdictions outsidethe District of Columbia." Compliance Fees The CAEA increasedthe compliance fees for Tier I and solar energy requirements. In particular,the Tier I fee is raisedfrom 2.5 cantsper kilowatt-hour to 5 centsper kilowatt-hour It Previously,the RPS statedthat in2022 and later, the RPS requirementwould be I I percentfrom Tier I resources,0 percentfrom Tier [I resources,and not less than 0.386 percent from solar energy. The CAEA did not explicitly statethat the RPS obligation is to continue after 2020. of shortfall. For solar energyresources, the compliancefee is raisedfrom 30 centsto 50 cents in 2009 until 2018 for eachkilowatt-hour of shortfall.re Distributed Generation Amendment Act of 2011 On October 20, 2011, the permanent version of the DGAA became law. The legislation amendedSections 34-1431-1439of the RenewableEnergy Portfolio Standard.2o These amendmentsto the statute are discussedbriefly below. The Commission addressed these statutory revisions, as appropriate,in a NOPR amending the RPS rules issued on January 13,2012. No commentswere receivedon the NOPR and the Commissionadopted the proposed amendmentsto the RPS rules in Order No. 16738 (March 15,2012). The arnendmentsto the RPS rules became effective upon publication of a NOFR in the D.C. Registeron March 23,2012. Solar Thermal Systems The DGAA amendedthe requirements for eligible solar thermal energy systems to remove the requirement that all such systemshave a certification from the Solar Rating and Certification Corporation("SRCC"). The new languageis as follows: "For nonresidentialsolar heating,cooling, or processheat property systemsproducing or displacing greaterthan 10,000 kilowatt hours per year, the solar collectors used shall be SRCC OG-100 certified and the energy output shall be determinedby an onsiteenergy meter that meetsperformance standards established by OIML." "For nonresidentialsolar heating,cooling, or processheat property systemsproducing or displacing 10,000or less than 10,000kilowatt hours per year, the solar collectors used shall be SRCC OG-100 certified and the energy output shall be determinedby the SRCC OG-300 annual systemperformance rating protocol or the solar collectors usedshall be SRCC OG-100 certified and the energyoutput shall be determinedby an onsiteenergy meter that meetsperformance standards established by OIML." "For residential solar thermal systems,the systemsshall be SRCC OG-300 system certified and the energy output shall be determined by the SRCC OG-300 annual rating protocol or the solar collectorsused shall be SRCC OG-100 certified and the energy output shall be determined by an onsite energy meter that meets performance standardsestablished by OML." These changesalso made it easierfor large nonresidentialsolar thermal systemsto participate in the RPS program as these larger systemsare able to meet the requirementsfor 't In the January2,2009 NOPR, the solar energy compliancefee was indicatedto be $300 for the 2008 complianceyear. 20 D.C. official Code$$ 34-1431- 1439(2olo Repl.& 2012Supp.). l0 the certification of solar collectors under SRCC OG-100, but not the system certification underSRCC OG-300. RPSSolar Requirements The DGAA amendedthe requirementsfor the RPS. In particular,beginning in 201l, the RPS solar requirementsincrease through 2023. By 2023,the DGAA requires2.5 percent from solar energy resources. Previously, the RPS requirementcalled for 0.4 percent from solar energyr"ro*.", by 2020.2r In addition,the DGAA legislationrestricted the location of eligible solar energyresources: "...an electricity suppliershall meet the solar requirementby obtainingthe equivalent amount of renewable energy credits from solar energy systemsno larger than 5 MW [megawatts] in capacity located within the District or in locations served by a distribution feederserving the District." Moreover,the DGAA included a "grandfathering"provision that exemptedelectricity supply contracts, signed prior to the effective date of the legislation, from the increasedsolar RPS requirements. The table below providesa comparisonof the estimatedMW of solar capacityneeded to meet the increasedsolar requirementunder the DGAA. As of April 19, 2016, the total capacityassociated with the solar energysystems certified for the District's RPS program is about 39.6 MW, of which about 19.2 MW is locatedin the District. The table also indicates the additional capacity required to meet the solar requirement in subsequentyears." 2t The DGAA also clarifies that the RPS obligation is to continue after 2023. 22 The estimated solar capacity figures under the DGAA do not take into account the "grandfather" provision for electricity supply contracts,which can reducethe solar capacityneeded. 11 lncremental MW Capacity Percentageof Sales Estimateof Solar Required(Year for SolarRequirement MW Required over-Yearl Year CAEA DGAA CAEA DGAA DGAA 2013 0.10 0.500 8.4 41.8 20L4 0.13 0.600 11.0 50.5 8.7 2015 0.77 0.700 14.3 59.0 8.5 2016 o.27 0.825 17.8 59.9 10.9 2017 0.25 0.980 27.3 83.4 13.5 2018 0.30 1.150 25.7 98.4 15.0 2019 0.35 1.350 30.1 116.1 t7.7 2020 0.40 1.580 34.5 136.5 20.5 2021 1.850 t50.7 24.1 2022 2.175 189.8 29.2 2023 2.s00 2t9.3 29.s SolarRPS Capacity (MW) 75 70 65 50 55 -fstslcapacity 50 Certified 45 -!f-$35sd Capacity 340 Ess Certified -Capacity Neededfor 30 RPS 25 20 15 10 5 0 sf st ii st sl sl In ul fr ul |/l In lo (O iiidi|HdFlrlF{dFldd E ! g i sat t 5 g i sai t s Gen eratio n Certift cation The DGAA also amendedthe requirementsfor certification: "After January 31, 2011, the Commission shall not certify any tier one renewable sourcesolar energy systemlarger than 5 MW in capacity or any tier one renewable t2 sourcesolar energy systemnot locatedwithin the District or in locations servedby a distribution feederserving the District." "Any tier one renewablesource solar energy system larger than 5 MW in capacity shall be decertifiedby the Commission. Any tier one renewablesource solar energy systemnot located within the District or in locations servedby a distribution feeder serving the District, first certified by the Commissionbetwean February I,20ll, and the applicability date of the Distributed GenerationAmendment Act of 2011, passed on 2nd readingon July 12,20ll (Enrolledversion of Bill 19-10),shall be decertified by the Commission." Compliance Fees The DGAA altered the compliance fees for solar energy. In particular, for each kilowatt-hour of shortfall from required solar energy sources,the compliancepayment is 50 centsin 20ll through2016;35 cents n2017;30 centsin 2018; 20 cents lrr'2019through 2020; 15 cents lrr2021through 2022; and 5 centsin2023 and thereafter. RenewableEnerw Portfolio Standard Amendment Actof}0l4 On April 30, 2015, the REPS Amendment Act of 2014 became effective. The legislation primarily affected the eligibility of qualiffing biomass resources. The amendmentsto the statute are discussedbriefly below. The Commission addressedthese statutory revisions, as appropriate, in an amendmentto the RPS rules that became effective upon publicationof a NOFR in the D.C. Registeron April 1, 2016. WS Compliance Requirements Under the DGAA, energysupply contractsentered into prior to August 1,20L1, shall not be subjectto the increasedsolar energyrequirement as requiredby law. However, as a result of the REPSAmendment Act, any extensionor renewalof such contracts,executed on or after August l,20ll, shall be subjectto the higher solar energyrequirement as requiredby law. This affects the ability of electricity suppliers to take advantageof the grandfather provision that was includedin the DGAA. Generator CertiJication and Eligibility The REPS Amendment Act, in part, requires qualifuing biomass facilities to meet a certainefficiency standardin order to be eligible as a Tier I resource. Thus, the Commission now requires every facility using qualifuing biomass to generateelectricity and certified as a qualiffing resource by the Commission to submit annually by June l, starting in 2016, informationdemonstrating each facility's total systemeffrciency for the currentcalendar year. l3 DeJinition s and Applicability The relevantchanges (in bold) to the definitions and applicability of the RPS statutes as implementedin the RPSrules are indicatedbelow: Black liquor - the spent cooking liquor from the Kraft processof paper making. Fuel input - the higher heating value of the input fuel type, measuredin BTU/LB, based on the standardized heating type of fuel type, multiplied by the annual fuel used in as delivered tons, multiplied by 2000. Oualiffine biomass - a solid, non-hazardous,cellulosic waste material that is segregatedfrom other wastematerials, and is derivedfrom any of the following forest- related resources, with the exception of old growth timber, construction and demolition-derived wood and whole trees that are not part of a closed-loop biomass system, cleared solely for the purpose of energy production, unsegregated solid waste,or post-consumerwastepaper Construction and demolition-derived wood and whole trees that are not part of a closed-loopbiomass system, cleared solely for the purpose of energy production, shall be considered qualifying biomass, if a) this material was used to generate RECs and those RECs are retired for compliance purposes with respect to electricity consumed by SOS customers on or before May 31, 2015; or b) this material was used by a facility certified before April30,2015, the effective date of the Renewable Energy Portfolio Standard Amendment Act of 2014, to generate RECs, which were purchased by an electricity supplier pursuant to a contract executed before April 30, 2015, and those RECs are retired for compliance purposes with respect to electricity consumed by non-SOS customers on or before December 31, 2017. In all other instances, the construction and demolition-derived wood and whole trees that are not part of a closed-loop biomass system, cleared solely for the purpose of energy production, shall not be considered qualifying biomass, as of April30,2015. Tier one renewablesource -- one (1) or more of the following typesof energysources: (c) Qualifying biomass used at a generation unit that achieves a total system efficiency of at least sixty-five percent (65%) on an annual basis, can demonstrate that it achieved a total system efficiency of at least 65oh on an annual basis through actual operational data after one year, and that started commercial operation after January 112007; The qualilications to qualifying biomass in subsection(c) shall not apply to RECs retired for compliance purposes with respect to electricity consumed by SOS customers on or before May 31r 2015; or with respect to electricity consumed by t4 non-SOScustomers on or before December31,2017, provided that theseRECs were produced by a facility certified as a Tier I energy source before April 30, 2015 and were purchased by an electricity supplier pursuant to a contract executedbefore April 30, 2015. In all other instances,subsection (c) shall apply asof April30,2015. Tier two renewablesource -- one (l) or more of the following typesof energysources: (c) Qualifying biomass used at a generation unit that started commercial operation on or before December 31, 2006; or achievesa total systemefficiency of lessthan 65Vo;or usesblack liquor. Subsection (c) shall not apply to RECs retired for compliance purposes with respect to electricity consumed by SOS customers on or before May 31, 2015; or with respect to electricity consumed by non-SOS customers on or before December 31, 2017, provided that these RECs were produced by a facility certified as a Tier I energy sourcebefore April 30, 2015 and were purchasedby an electricity supplier pursuant to a contract executed before April 30, 2015. In all other instances,subsection (c) shall apply as of April 30, 2015. Total svstem efficiencv - the sum of the net useful thermal energy output measuredin BTUs divided by the total fuel input. Useful thermal enerev output - energy in the form of direct heat, steam, hot water, or other thermal form that is used in production and beneficial measures for heating, cooling humidity control, processuse, or other valid thermal end use energy requirements and for which fuel or electricity would otherwise be consumed. Useful thermal energy output does not include thermal energy used for the purpose of drying or relining biomassfuel. III. RPS ComplianceReports for 2015 Pursuantto the Commission's RPS rules, all active electricity suppliers with retail salesin 20I5-a total of thirty-three (33) suppliers-submitted a compliancereport due by April l, 2015 for that calendff year: including Agera Energy; Ambit Energy; AEP Energy; ChampionEnergy Services;Clearview Energy; ConsolidatedEdison Solutions;Constellation NewEnergy;Constellation Energy Services;Devonshire Energy; DC Gas and Electric; Direct Energy Business;Direct Energy BusinessMarketing; Direct Energy Services;Eligo Energy; Energy.me;Ethical Electric; GDF Suez Energy ResourcesNA; Horizon Power and Light; IDT Energy; Liberty Power; MidAmerican Energy; NextEra Energy Services; Noble Americas Energy Solutions;Potomac Electric Power Company("Pepco"); Public Power; Reliant Energy Northeast; Starion Energy; Stream Energy; Talen Energy Marketing; UGI l5 Energy Services;Viridian Energy; WGL Energy Services;and XOOM Energy.2t Suppliers met the RPS requirementsthrough acquiring RECs or making a compliancepayment. Renq,vableEnergt Credils ("RECs") and CompliancePayments All of the electricity suppliersdid not have to pay a compliancefee in order to meet the Tier I or Tier II requirementsin 2015.24Prior to the adoptionof the DGAA legislation, electricity supplierswere requiredto "exhaustall opportunities"to acquireRECs from solar energy systems located within the District before going outside the jurisdiction. The requirementto "exhaust all opportunities" to acquire District solar RECs first is no longer included in the DGAA. Instead,the DGAA provides that electricity suppliersshall meet the solar requirement by obtaining the equivalent amount of RECs from solar energy systems,no larger than five megawatts(5 MW) in capacity, which are located within the District of Columbia or in locations servedby a distribution feeder serving the District of Columbia.2s The law also provides that RECs generatedby solar energy facilities that are not located within the District of Columbia nor in locations servedby a distribution feeder serving the District of Columbia but were certified by the Commissionprior to February 1,2011, may alsobe usedto meet the solarrequirement. Theseare referred to as "grandfathered"facilities. As a result of the DGAA, in Order No. 16529,issued on September9, 2011, the Commissiondecertified 1,426solar energyfacilities. Thus, for the 201I complianceyear and beyond, any RECs submitted from decertified solar energy facilities will not be accepted. Basedon the Commission'sreview of the solar RECs retired for RPS compliance,electricity suppliers did not submit RECs from decertified solar facilities in order to satisfy their requirernentsin 2015. Moreover, the majority of the electricity suppliersdid not provide sufficient solar RECs ("SRECs") to avoid payng a compliance fee for the solar requirement.26 The compliancepayments have increasedsubstantially in recent years. Basedon the available information, the total amount of money raised from compliance payments was $19,910,000in 2015,up from $6,308,710:rr.2014 and $699,140generated in 2013.27The substantialincrease in the compliancefees, compared to 20L4, generallyreflects the inability 23 As the provider of StandardOffer Service, Pepco compiles a report basedon the compliance of its wholesaleelectricity suppliers. 24 For 2015, the Tier I requirementwas 9.5 percentand the Tier II requirementwas 2.5 percent. For 2016, the Tier I requirementrises to I 1.5percent and the Tier II requirementdeclines to 2.0 percent. 2s The Fiscal Year 2015Budget SupportAct of 2014 amendedthis to allow systemsexceeding 5 MW on District governmentfacilities. 26 RECs that are retired for RPS complianceare placed in a specialaccount so that they can no longer be used. 27 The compliancepayments are sent directly to DOEE and the funds are depositedinto the Renewable Energy DevelopmentFund. t6 of suppliers to acquire sufficient solar RECs to meet their RPS compliance.28 The total compliancepayments submitted in variousreporting years are provided in the table below:2e CompliancePayments Total 2007 $199,490 2008 $399.320 2009 $429.320 2010 $s5,850 2011 $229,500 2012 $4,900 2013 $699.140 2014 $6.308.710 2015 $19,910,000 The DGAA includes a "grandfathering" provision that exempts electricity supply contracts,signed prior to the effective date of the legislation (August l, 20Ll), from the increased solar RPS requirements. The current reporting form asks electricity suppliers to report on the retail sales subject to the higher DGAA requirement and the retail sales subject to the previous RPS requirement. The responsesprovided resulted in an overall share of abofi99.2 percent-up from82.2 percentlast year 2E While the solar carve out percentagerequirement of the DGAA increasesover time, the price of the Alternative CompliancePayment ("ACP") for the solar requirementwill currently decline afrer 2016. By 2023 the price is set at one-tenth($50 per solarREC shortfall) ofthe currentcompliance fee level ($500 per solar REC shortfall). Since the price ofthe ACP acts as a cap on the solar REC price, the revenuestream from this source will decreaseover time. 2e In 2OO7and 2008, the compliancepayments generally resulted from electricity supplierspalng the solar compliancefee to meet the solar requirement. In 2009, the increasein the compliancepaynent from the previous year was due, in part, to the increasein the solar compliancefee from $300 to $500 per REC-as a result of the CAEA. In 2010, as a result of the substantialincrease in approvedsolar energysystems, electricity supplierswere generally able to acquire a substantialnumber of solar RECs insteadof paying the compliance fee. In 2011, the jump in the compliancepayment was due to one electricity supplier failing to obtain solar RECs and, thus, having to pay the compliancefee. This particular supplier accountedfor the majority of the compliancefees-$225,500 out of a total of $229,500. Ilt 2012, supplierswere largely able to meet the RPS throughREC purchasesand were subjectto only $4,900in compliancefees. I7 RetailSales Subject to DGAA Some suppliersused Tier I RECs to meet their Tier II requirementbased on $ 34- A33(a)(2) of the D.C. Official Code, which indicatesthat energyfrom a Tier I resourcemay be appliedto the percentageRPS requirementsfor either Tier I or Tier II renewablesources.'" Nearly 40 percent of the Tier I RECs used for compliancewere from facilities using wood waste. Other qualifying biomassresources (black liquor), wind resources,and methanefrom landfill gas accountedfor roughly 26 percent,2Opercent and l0 percent,respectively, of the Tier I RECs. In addition, ffi & result of the Fiscal Year 2015 Budget SupportAct of 2014, solar facilities locatedin PJM or in a stateadjoining PJM may be certified by the Commission and their RECS may be used by electricity suppliersto meet the Tier I renewableresource requirernentthat falls outsideof the DC-basedsolar requirement. The Commissionapproved a 39 MW facility in Georgia that provided RECs for the 2015 compliance year, which accountedfor a little less than 2 percent of the Tier I resources. Solar energy resources amountedto about 3 percentof Tier I RECs.3l Tier II RECs were entirely from hydroelectric facilities, as municiial solid waste is no longer eligible for compliuttce putposes." A breakdownof the number of RECs submitted in 2015 by fuel type is provided in the table below: 30 In particular, nine (9) of the suppliersused Tier I RECs to meet the Tier II requirement,with seven(7) out of the 9 suppliersusing only Tier I RECs. 3r In the 2014 complianceyear, black liquor RECs accountedfor nearly 50 percentof the Tier I RECs and wind RECs representedroughly 7 percentof Tier I. Wood wastemade up about 32 percentof the Tier I RECs. ln addition, the use of methanefrom landfill gasw:ts 7 percent. 12 Order No. 17350 (issued January 13, 2014) decertified the two municipal solid waste facilities previously approvedfor the RPS and noted that the MSW RECs from thesefacilities were no longer eligible for RPS compliancepurposes in 2013 and going forward. 18 RenewableEnergy Credits Submifted fior 2015 Gompliance No. of RECs Share of Tier TierI Resource Black Liouor 301.405 26.5o/o lvlehanefrom LandfillGas 109.724 9.6% Wind 225.80 19.8o/o WoodWaste 4,r'i5.786 39.2Yo l,lon-SolarTier | (out-of-statesolar) 17.918 1.6% Solar 38.167 3.4o/o TotalTierI 1,138,480 100.0% 'l'ier ll Resource l-lydroelecfic 220,528 100.0% MunicioalSolidWaste 0.0o/o TotalTierI and ll 1.359.008 Electricity supplierssubmitted RECs from2012 through 2016. About 0.01 percentof the RECs used for compliancewere generatedin 2012, while 24.8 percentof the RECs were generatedn 2013, with roughly 49.5 percent generatedrn 2014, 25.6 percentgenerated in 2015, and,0.04percent generatedlu;.20L6. Section 2903.2 of the RPS Rules indicatesthat RECs shall be valid for a three-yearperiod from the date of generation,beginning January 1, 2006, exceptwhere precluded by statute. In 2015, electricity suppliersprovided the REC prices for all of their resources. The rangeand weighted averageof the reportedREC prices for 2007 through 20l5,by fuel t1pe, is provided in the tablebelow:" AvengePrice ofRepoiled Conplhnce RECs m7 2008 2009 n10 n11 n12 n13 n14 n15 Iier| fusource BlackLiouor $1.56 $0.01 $1,30 $o.go $1.94 $2.74 $2,78 $1.81 $1.20 lilehanefrom hndfii Gas $1.03 $0.84 $0.82 $1.51 y.a $2.2 $2,51 $2.46 $2.84 Wind M $1.24 m.47 M $2.67 $2.37 $2.38 $2.55 $2.15 WoodWasb $0.ss $o.z+ $0.60 $0.67 $1.58 $z.n $2.40 $2.07 $1.62 l{onsohrTier | (out-of-shtesohr) M M M M M M M M $1.00 Sdar M M $4S.90 $51.m $300.16 $327.59 $364.75 $416.50 $435.12 lierll Fbsource Ftvdroelectic $0.51 $0.55 $0.59 $0.41 $0.s0 $0.m $1.12 $1.13 $0.s2 [turicipalSolidWa$e $1.00 $0.71 $0.66 $0,78 $0.43 $0.60 M M M As seenin the abovetable, non-solarREC prices have been relatively stablein recentyears, despitethe rise in RPS requirements,over time, acrossstates. However, solar REC prices for 33 A R€C representsone megawatt-hourof electricity anributable to a particular renewable resource. Prior to 2014, not all of the electricity suppliers fully reported their REC prices, Recent 2016 solar REC ("SREC") prices from the Flett Exchangeare trading around $480 per REC. l9 the Dishict have trended upward since 201I as the impact of the DGAA has made the District's solarREC pricesthe highestin the region. Taken together,the estimatedtotal cost of compliance-including the cost of RECs and compliancefees-amounted to nearly $39 million for the 2015 RPS compliance,up from $27 million for the 2014 RPS compliance. The increasein the solar RPS requirementover time will continueto placeupward pressure on the cost of compliance. IV. The Availability of RenewableResources This sectiondiscusses the availability of Tier I renewablesources, as requiredin the REPS Act. The issueof availableresources is affectedby geographicrestrictions in the RPS. The REPS Act indicated that a: "Renewableenergy credit" or "credit" meansa credit representingone megawatt-hour of electricity consumedwithin the PJM InterconnectionRegion that is derived from a Tier I renewablesource or a Tier II renewablesource that is located: l. In the PJM Interconnectionregion or in a state that is adjacent to the PJM InterconnectionRegion; or 2. Outside the area describedin subparagraph(1) of this paragraphbut in a control area that is adjacant to the PJM Interconnectionregion, if the electricity is delivered into the PJM InterconnectionRegion. The REPS Act did not provide a definition for adjacent states or an adjacent control area. In its third report in 2005, the RPS Working Group was not able to reacha consensuson the definition of "adjacent" states md, thus, presented two different interpretations. Ultimately, the Commissionadopted the broaderdefinition of "adjacenf' and determinedthat states "adjacent" to the PJM Interconnection Region should help lessen the cost that ratepayerswill have to pay for the renewableportion of their fuel mix." In particular, the following statesare currently deemedadjacent to PJM: Alabama,Arkansas, Georgia, Iowa, Mississippi,Missouri, New York, SouthCarolina, and Wisconsin. Thus, from the outset,the District's RPSprogram allowed a relatively broadgeographic participation. Subsequently,the Fiscal Year 201I Budget Support Act of 2010 anended the definition of a REC to read as follows: "Renewableenergy credit" or "REC" meansa credit representingone megawatt-hour of energyproduced by a tier one or tier two renewablesource located within the PJM 34 The RPS rules indicate that stateswithin the PJM InterconnectionRegion are currently defined to include: Delaware, the District of Columbia, Illinois, Indiana, Kentucky, Maryland, Michigan, New Jersey, North Carolin4 Ohio, Pennsylvania,Tennessee, Virginia, and West Virginia. 20 Interconnectionregion or within a state that is adjacentto the PJM Interconnection regionrj The changein the definition of a REC actually made it easierfor the Commissionto approve renewable energy systemslocated in states adjacent to the PJM Interconnection Region. That is, the previousdefinition's referenceto "electricity consumedwithin the PJM InterconnectionRegion" suggestedthat at leastthe potentialto deliver electricity was required in order for a renewableanergy system to be approvedfor the District's RPS program. As a result, prior to the changein the REC definition, the Commissiondenied several applications from solar generator systems located in New York. In its decisions, the Commission generallyindicated that the applicantdid not provide sufficient information to demonstrateor documentthe amount of energy that can be delivered into the PJM Interconnection Region for consumption.36However, the new definition refers only to where the energy is produced, not consumed. As a result of the revised statutory REC definition, the Commission began approvingsolar generatorapplications from statessuch as New York and Wisconsin in 2010; however,with the passageof the DGAA, out-of-statesolar energysystems are now generally not eligible to be certified by the Commissionfor generationof SRECsfor compliancewith the solar portion of the RPS. However,pursuant to the clarification languageincluded by the Council in the Fiscal Year 2015 BudgetSupport Act of 2014, out-of-statesolar facilities may be certified for use in complying with the non-solarportion of the Tier I RPSrequirement. The table below provides a measureof some of the renewableresources available in the PJM region for 2015. The following information providesa perspectiveon the renewable resourcesin the PJM region associatedwith the generationof electricity. Basedon the table below, the overall renewableresources in the PJM InterconnectionRegion representsroughly four percent of the available fuels. Wind power accounts for the largest share among renewable resotuces,about two percent. Among other renewable sources,hydroelectric power representsthe secondlargest resource-around one percent-followed by municipal solid waste-less than one percent. For 2015, only hydroelectricpower would be countedas a Tier II resourceunder the District's renewableportfolio standardas municipal solid waste no longer qualifies as a renewableresource. ^_Methane gas and biomass-relatedfuels are approximately0.3 to 0.2 percent,respectively." Taken together,Tier I relatedresoruces as defined by the District r€present a very small share of the current fuel mix in the PJM system-approaching 3.0 percent. 35 D.c. officialcode g 34-t431(10)(2012 Supp.). 36 SeeOrder No. 15699@ebruary 23,2OlO), Order No. 15775(April 20,2OlO),and Order No. 15812 (May18,2010). 37 Coalmine methane gas is not generallyeligible under most RPS policies. 2l PJM System Fuel Mix 2015 Fuel Share Coal 36.6% Nuclear 3s.8% NaturalGas 23.O% oil o3% Hvdroelectric 1,0% OtherRenewable 3.3% CapturedMethane Gas (Landfill or CoalMine) 0.3% Geothermal o.o% SolarPV o.t% MunicipalSolidWaste o.5% Wind 2J% Wood,other biomass 0.2% TotalRenewable Resources 4.3% Total 100.0% Source:PJM-EIS GATS Through the Reliable Energy Trust Fund, DOEE previously administered the RenewableEnergy DemonstrationProject ("REDP"), approvedby the Commissionin Order No. 12778(July 9, 2003). The objectiveof the REDP was to increasethe awarenessand use of renewableenergy grid-connected technologies by District ratepayers.Ttirough the REDP, DOEE awarded grants to help finance renewable energy projects in the District. The CAEA replacedthe REDP with the RenewableEnergy IncentiveProgram ("REIP"). As of April 19, 2016, there are4,545 renewablegenerators eligible for the District's RPS program. Of thesefacilities, 4,516 (roughly 99 percent)use Tier I resources(including biomass,methane from landfill gas,solar, and wind) and,29(roughly one percent)use Tier II resources(including hydroelectric).3ESince theserenewable generators may be certified in other statesthat have a RPS as well, the RECs associatedwith the generatingcapacity are not necessarilyfully availableto meet the District's RPS requirement.The table below providesa breakdownof the renewablegenerators by fuel tlpe and location: This will changeafter the Commissionreclassifies the biomassresources later this year. 22 Numberof RenewableGenerators by Fuel Type and Location (asof April19,2016) Methane from SolarPV Solar BiomassHvdroelectric landfill SolarPV (NSTr)Thermal Wind Total Districtof Columbia 2,022 102 2,t24 Alabama I I Delaware 2 L49 1 152 Georgia 3 1 4 lowa t 1 lllinois 1 22 7 L4 44 Indiana L4 42 8 64 Kentucky 2 5 55 1 64 Itrlaryla nd I 2 ztl 1 10 225 Michican 1 3 6 10 NorthCarolina 4 1 78 78 161 rrlewJersey 8 8 \ew York I 28 I 30 f,hio 2 I 2 128 1 4 2 140 )ennsvlvania 4 7 913 15 6 946 [ennessee 1 1 Virginia 5 9 9 373 r20 517 Wisconsin I 1 11 13 WestVirginia 6 24 7 3 40 Total 18 29 66 4,055 3 340 34 4,545 Note: Biomassincludes black liquor and wood/wood waste. The District has also made significant progressin certifying solar energyfacilities for the RPS program. Currently, as of April 19, 2016,4,395 solar energy systems-including solar photovoltaicand solarthermal-are eligible to participatein the District's RPSprogram. Within the District, there are crrrently 2,022 approvedsolar photovoltaic("PV") systemsand 102 solar thermal systems." Outside of the District, there are six stateswith more than 100 eligible solar energysystems including Pennsylvania(929),Virginia (493), Maryland (22I), North Carolina (156), Delaware (150), and Ohio (132). These six (6) states account for roughly 92 percent of the non-DC solar energy systemsapproved for the District's RPS program. Solar energysystems can be found in all eight wards of the District. To date rn 2016, the numberof RPS-eligiblesolar energysystems has increasedin all wards. The figure below showswhere the systemscertified for the District's RPSprogram are located: 3e The Commission provides monthly updates on solar energy system certifications and solar REC pricing, availableat the following link htto://www.dcpsc.ore/Electric/Renewable.asp 23 CertifiedDistrict Solar Energy Systems by Ward Ward8 Ward7 Ward 5 Ward 5 Ward 4 Ward 3 Ward2 Ward 1 100 150 200 2s0 300 3s0 r April15, 2015 I April19, 2016 The total capacity associatedfor all solar energy systemsis about 39.6 megawatts ("MW'), with about 19.2 MW located in the District as of April 19, 2016 and 18.5 MW locatedin the District as of Decernber31, 2015, comparedto 15.0MW locatedin the District as of April 15,2015 and 13.3MW locatedin the District as of December31, 2014.40The current solar capacityis lessthan the 59.0 MW of estimatedsolar capacltynecessary to meet the RPS requirernentof 0.70 percent in 2015 requiredby the DGAA and less than the 69.9 MW of estimatedsolar capacitynecessary to meet the 0.825 percent ln2016 requiredby the DGAA.4I As noted above,many of thesesolar energysystems are certified in more than one jurisdiction, so it is diflicult to determinewith precisionthe resourcesthat are fully available to meet the District's RPS requirement. However, the District's solar REC prices are the highest in the region, so holdersof solar RECs have a significant financial incentive to sell them to electricity suppliers who need to satisfu the solar requirement in the District. Specifically, the price of the District's solar RECs is very close to the $500 compliancefee. In addition,the "grandfather"provision that was included in the DGAA in 201I for electricity supply contracts that protected a portion of the electricity sales from the revised RPS requirementshas largely run its course. The table below shows the capacity of all of the District's certified renewablegenerators, by fuel type and location,as of April 19,2016: 40 Within the District, there are 28 certified solar energy systemswith a reported capacityof at least 100 kW. The largestsystem is locatedat Dunbar High School and has a reportedcapacity of 463 kW. 4r These estimated solar capacity figures do not take into account the "grandfather" provision for electricity supply contracts. 24 Capacity(MW) of RenewableGenerators byFuelType and Location (asof April19, 2016) Methane from SolarPV Solar BiomassHydroelectriclandfill SolarPV (NSTr)Thermal Wind Total Districtof Columbia 14.3 5.0 19.2 Alabama 87.5 87.5 Delaware 7.4 L.2 0.0 8.6 Georeia 284.4 38.7 323.1 owa 200.0 200.0 llinois 3.0 1t4.4 0.5 1,614.2 1,732.7 ndiana M.0 0.2 1,201.9 1,246.1 (entuckv 148.0 16.8 0.2 0.0 165.0 Varyland 65.0 494.0 1.6 0.0 0.0 560.6 Michigan 103.0 33.0 0.0 136.0 NorthCarolina 2t5.2 5.0 r.7 0.2 222.2 NewJersev 0.2 0.2 NewYork 34.8 0.4 0.0 35.2 Ohio 109.3 47.4 8.0 1.1 0.0 0.0 311.2 477.r Pennsylvania 467.5 55.4 10.0 0.0 371.0 904.0 Iennessee 50.0 50.0 Virginia 398.7 t47.2 43.7 2.7 0.4 592.t Wisconsin 44.6 9.1 0.1 53.8 WestVirginia 194.6 0.1 0.0 462.t 556.9 Total 1,290.5 r,6t2.8 327.7 33.9 38.7 5.7 4,160.4 7,469.6 Note: Biomassincludes black liquor and wood/wood waste. In 2015, the Commissionreceived 717 renewablegenerator applications-primarily involving the certification of solar generatorsfor the RPS program. As of April 15, 2016, the Commission has received 146 applications. The Commission continuesto approve solar energyapplications based on the existing laws and regulations. The chart below showshow the number of applications has changedover the years: 25 ConservingNatural Resourcesand Preservingthe Environment (Number of RenewablePortfolio Standard ApplicationsReceived) 2,200 2,100 2,000 1,900 1,800 1,700 't,600 1,500 1,400 1,300 1,200 1,100 1,000 900 800 700 600 500 400 300 200 100 0 V. Recent Activity and Next Steps The Commissionaddressed the changesthat were adoptedby the Council in the Fiscal Year 2015 Budget SupportAct of 2014 in a Notice of Final Rulemaking('NOFR") that appearedin the D.C. Register on October 30,2015. This Act amendedthe RPS statutesto allow solar energy systemslarger than 5 MW in capacity locatedon property owned by the District, or by any agency or independent authority of the District, to meet the solar requirement. It also clarified that solar facilities locatedin PJM or in a stateadjoining PJM may be cenified by the Commissionand their RECs may be used by electricity suppliersto meet the Tier I renewable resourcerequirement that falls outside of the DC-based solar requirement. The Commission also addressedthe changesto the eligibility of biomass facilities pursuantto the RenewableEnergt Portfulio StandardAmendment Act of 2014, passedby the Council on December17, 2014,in a NOFR that appearedin the D.C. Registeron April l, 2016. Among other things, this legislation impacted the eligibility of RECs retired from biomassfacilities for the 2015 reporting year ln addition, this legislation would reclassify a majority of the biomass(including black liquor) facilities as Tier II resources,because they begancommercial operation on or beforeDecember 31,2006. The Commissionaddressed the matter with the electricity suppliersby contacting suppliersto confirm if they were in compliance and, if appropriate,requesting that alternative RECs be submitted to ensure 26 compliancewith the RPS requirements. In addition, the Commission is in the processof changingthe certification statusof the biomassfacilities that do not comply with the new law. The Commissionalso continued the processto implementcommunity net meteringin the District. On December13, 2013, the CommunityRenewable Energt AmendmentAct of 2013 (D.C. Law 20-0047or "CREA"), which was enactedbythe Council of the District of Columbia, becamelaw. Among other things, CREA allows for the creation of community renewableenergy facilities ("CREFs") of up to 5 MW wherein two or more "subscribers"can share the electricity produced by a single CREF. The Commission addressed the implementationof community net metering under the CREA with a September12,2014, Notice of Proposed Rulemaking ("NOPR") in the D.C. Register on which numerous commentswere received. After reviewing commentson the first NOPR, the Commission submitteda secondNOPR, which appearedin the D.C. Register on January 30,2015. On April23,2015, the Commissionvoted to adopt the final rules implementingCREA in Order Nos. 17862and 17863. The rules becamefinal upon publicationof the NOFR in the D.C. Registeron May 8, 2015. On December11, 2015,the Commissionissued Order No. 18050, approving the CREF Documents submitted by Pepco and directing Pepco to make certain amendmentsto the CREF Documents,including the CREF Contact. On January II,2016, Pepco filed its Application for Reconsiderationof Order No. 18050, and OPC filed its responseon January19,2016. In OrderNo. 18135(issued March 3,2016), the Commission grantedthe motionof Pepcoto reconsiderthe Commission'sdecision in OrderNo. 18050and Pepcowas directedto modiff the CREF Contractconsistent with this Order. With this Order, the Commissioncompleted its legislativelyassigned tasks for the implementationof CREA. Going forward, the Commission will continue to certiff generating facilities and update information on approved generatorson the Commission's website. Through its website, the Commission is making forms and the rules available, to help facilitate the certificationand complianceprocess. In addition,the Commissionwill continueto maintain a list of approvedrenewable generating facilities on the Commission'swebsite. Moreover, the Commissionhas made availableon its website fact sheetsthat explain net energymetering, which allows customer-ownedgenerators (including renewableenergy systems)to generate and sell excesselectricity back to the grid, and the processfor certi$ing a renewableenergy systemfor the District's RPS program. The Commission'swebsite also providesmonthly updateson solar energy system certifications and solar REC pricing. Additional program information will also be made available as deemedappropriate. The Commissionmonitors the interconnectionsprocess to ensurethat applicationsfor the interconnectionof renewable generatingfacilities in the District are made on a timely basis. Finally, we will continueto monitor the development of relevant Council legislation regarding RPS and goals for renewablesin the District. As needed,the Commissionwill continueto adoptregulations or ordersgoverning the implementationof the RPS. 27 Attachment I RenewablePortfolio Standardsin Other States 28 RenewablePortfolio Snndards in Other Statesl According to the Databaseof StateIncentives for RenewableEnergy ("DSIRE"), 29 statesand the District of Columbiahave adoptedRPS policies or mandates.In addition,eight stateshave renewableenergy goals (seeFigure l). The 29 statesinclude Aizona, Califomia, Colorado, Connecticut,Delaware, Hawaii, ilinois, Iowa, Maine, Maryland, Massachusetts, Michigan, Minnesota, Missouri, Montana, Nevada, New Hampshire, New Jersey, New Mexico, New York, North Carolina, Ohio, Oregon, Pennsylvania,Rhode Island, Texas, Vermont, Washington,and Wisconsin. In 2015, Hawaii substantiallyincreased its renewable energy requirements,while Vermont switched from a non-binding goal to an RPS mandate. Finally, on March ll, 2016, Oregon's Governor signed legislation that will effectively eliminate coal from the electricity supply of the state'smajor utilities by 2030. The law also increasesthe OregonRPS from a pre-existing25 percentby 2025 to 50 percentby 2040, with interim goals along the way, starting n 2025 with 27 percent. Oregon joins Califomia, Hawaii, and Vermont as stateswith RPS laws of 50 percentor more. In February 2015, West Virginia repealedits RPS standard,which was enactedin 2009. West Virginia had adoptedan alternativeand renewableenergy portfolio standardthat was unique to the state. Specifically, West Virginia's standarddid not appearto require a minimum contribution from renewableenergy resources,and it is feasiblethat the standard could have been met using only alternativeresources and no renewableresources (as defined in the law). Thus, the renewableportion of the standardfunctioned more like a non-binding goal. Another distinguishingcharacteristic of West Virginia's standardwas the use of the term "alternative energy resources,"which was defined more broadly than definitions of altemative energy in other states. In particular, West Virginia's "alternative energy resources"included advancedcoal technology,coal bed methane,natural gas, fuel produced by a coal gasificationor liquefaction facility, syntheticgas, integratedgasification combined cycle technologi-es,waste coal, tire-derived fuel, pumped storagehydroelectric projects, and recycledanergy.' In May 2015, Kansasalso took a major stepwhen it switchedfrom an RPSmandate to a non-binding goal. [n June 2015, the Hawaii legislatureupdated legislation increasingthe state'smandate to 100 percentin2045-with interim requirementsof 30 percentby 2020,40 percent by 2030, and 70 percent by 2040. This makes Hawaii the first state with a 100 percent RPS requirement and is now considered a test bed for understandinghow to safely and reliably integrate very high proportions of intermittent and distributed generation t This section draws from material available at www.dsireusa.ore(Database of State Incentives for RenewableEnergy), Clean Energy StatesAlliance, Lawrence Berkeley National Laboratory, and the National Conferenceof Statelrgislatures. ' R""ycled energymeans useful thermal, mechanicalor electrical energyproduced from: (i) exhaustheat from any commercial or industrial process; (ii) waste gas, waste fuel or other forms of energy that would otherwise be flared, incinerated,disposed of or vented; and (iii) electricity or equivalent mechanicalenergy extractedfrom a pressuredrop in my 86, excluding any presswe drop to a condenserthat subsequentlyvents the resulting heat. 29 resources,such as solar, into the distribution grid. Vermont also passeda bill in June 2015, establishing an RPS requirement of 75 percant by 2032-with an interim requirement of 55 percent by 2017 and then increasing by an additional four (a) percent every three years until reaching the final requirement by 2032. The 29 statesinclude Pennsylvania'sAlternative Energy Portfolio Standard,which allows non-renewableresources that the state considersto be "environmentallybeneficial," such as waste coal.3 Ohio also adopted an alternative energy-renewable and advanced- resourcestandard with an overall target of 25 percent by 2025.4 However, the state has renewableresource benchmarks that begin in 2009 and increaseannually towards an eventual targetof 12.5o/oof retail electricity salesby 2024 andthereafter.s In addition, eight states-Alaska, Indiana, Kansas, North Dakota, Oklahoma, South Carolina, South Dakota, and Virginia-have non-binding renewable energy goals. South Carolina was the latest state to establisha goal n 2014. Utah also enactedlegislation in March 2008 that contains some provisions similar to those found in renewableportfolio standardsadopted by other states. However, certainprovisions in the legislationmay be more accuratelydescribed as a renewableportfolio goal.o Specifically,the legislationrequires that utilities only need to pursue renewableenergy to the extent that it is "cost-effective." The guidelines for determining the cost-effectivenessof acquiring an energy sourceinclude an assessmentof whether acquisition of the resolrce will result in the delivery of electricity at the lowest reasonablecost, as well as an assessmentof long-term and short-termimpacts, risks, reliability, financial impacts on the affected utility, and other factors determinedby the Utah Public Service Commission. To the extent that it is cost-effectiveto do so, investor- owned utilities, municipal utilities and cooperative utilities must use eligible renewable resourcesto accountfor 20o/ooftheir 2025 adjustedretail electric sales. ln addition,the first year of compliance is 2025 with no interim targets,but utilities must file progressreports during the interim period at specifiedtimes. The progressreports are supposedto indicatethe 3 The 8% in Figure I applies only to the Tier I resourcesunder Pennsylvania'sAlternative Energy Portfolio Standard.However, eligible Tier I resourcesalso includescoal mine methanegas, which is not eligible under most RPS policies. Pennsylvaniaalso has a Tier tr that includes some nonrenewableresources such as waste coal and also takes into account integrated combined coal gasification technology. The Tier tr requirementis l0%, yielding anlSVo total from alternativesources. o Eligible renewable resourcesare defined to include the following technologies: solar photovoltaics (PV), solar thermal technologiesused to produce electricity, wind, geothermal,biomass, biologically derived methanegas, landfrll gas, certain non-treatedwaste biomassproducts, solid waste (as long as the processto convert it to electricity doesnot include combustion),fuel cells that generateelectricity, certain storagefacilities, and qualified hydroelectric facilities. Generally, advancedenergy resourcesare defined as any process or technology that increasesthe generation output of an electric generating facility without additional carbon dioxide emissions. The definition of advancedenergy resourcesexplicitly includes clean coal, generationIII advancednuclear power, distributedcombined heat and power (CHP), fuel cells that generateelectricity, certain solid wasteconversion technologies, and demandside managementor energyefficiency improvements. t Only the renewabler€source portion of Ohio's requirementis reflectedin Figure I below. u For purposesofpreparing Figure I below, Utah's RPS program is consideredto be a voluntary goal. 30 actual and projected amount of qualiffing electricity the utility has acquired, the sourceof the electricity, an estimateof the cost for the utility to achiwe their target and recomme,ndations for a legislative or program change. The following comparesthe District's RPS requirementto nearbystates:7 o District - 2lo/oby 2023 (the solar require,mentincreases to 2.So/oby2023) o Delaware-2So/oby 2025-26 o Maryland-20o/oby2022 o New Jersey- 24.5o/oby2027-28 o North Carolina- 12.5o/oby2021 o Pennsylvania-8%by2020-21 o Virginia - l1o/oby2025 ' This does not account for differences in eligible resources, specific resourcc requirements, and other factors. 3l (\ o lO N ip s8 o @ (r) ON N N ?= n I I N =;: o F oLi. I N rf) og6l N c=- z N s rO L90 N;R N.ao o NR N s cr)0 N o u) oEg0 Sx u) I N N - o Eo'i CF F ol RB N ae se) RF NI S- ll >o(, ..N .Ct .ct 46E F ol E'5 tt tre nk NI JF s o-U, G' su?s :Sct Z=? Ha N ro C'N lt 4t =ao = ilB t N N -€z !t ro :S- ett N E6t F b$ =oL ri'i --g ciq _..o *:ils aBo= o o o e-N !ZNC' =o Z-N rffi 3.=6 !t :\ ct L a rN (E o x lo I !t o o)s N e tr F N (r E t (o +, N N I c 2 lt rF F o t @ o N o o T (o $Ht o N .9 = P"F I t) I rO o ZB tr o N o I o s N L o .cl o E- rO ta o. N rF s: 6l .-i llo -o FI iiN = .rN -9 OR 5a ta -cl ro v; (E ufe F N orc o E (\ c = E i"- rlo Aro b! o tt o \6 g tFN N E.9 s lt E= o O-" o rrZ .Ct ;q EE '^'YL t o I 6,= ci s =4 .I g z o EE F c QL o o S€ L r,6 I SF = o ra '= .9 TL lr o ttr g>$H tx -!l xra E6l €€E 2.2 :o Hs 22 2ti 5E ;€ro d6!egF6a(/) ON NO ..N F> 3rl Attachment 2 List of SelectedCommission Orders and Noticeson the Implementationof the RenewableEnergy Portfolio Standard 33 List of SelectedCommission Orders and Notices on the Implementation of the RenewableEnergy Portfolio Standard Order No. 13566(April 29. 2005): lnvited interestedparties to submit their views on twelve (12) RPS-relatedissues. Order No. 13766 (September23. 2005): Addressedvarious issuesbased on the comments filed in responseto Order No. 13566. With respectto the processfor implementingthe Act, the Commission directed interestedparties to form a RPS Working Group to examine in more detail certain issuesrelated to the implementation of the REPS Act, and to develop a timeline and recommendationswith respectto a two-phasedapproach to resolving those issues. The Commission also indicated that the PJM Environmental Information Service ("PJM-EIS") GenerationAttribute Tracking System("GATS") would be usedin the implementationof the Act. Order No. 13795 (October 24. 2005): Adopted the RPS Working Group's proposed proceduralschedule recommended in the RPS Working Group Report (submittedOctober 11, 2005), including a timeline and designationof items, for addressingPhase I and PhaseII issues-raisedin OrderNo. 13766. Order No. 13804(November 10. 2005): Acceptedin part and rejectedin part commentsfiled by the parties in the RPS Working Group Report submitted on October 25,2005. The Commission generally approved the method for certifying individual generators. The Commission directed the RPS Working Group to develop a list of comparable state certificatesthat would meet the District's RPS. The resulting list would help identiff which facilities are in compliancewith the District's RPS requirements.However, the Commission rejectedthe accrual of retroactiveRECs createdbefore January l, 2006. The Commission noted that the intent of the REPS Act is to encouragethe production and siting of renewable resourcesgoing forward, rather than looking back, which reducesthe need for the use of retroactiveRECs. Order No. 13840 (December28. 2005): Approved, in part, various rules addressingPhase I issues recommendedin the RPS Working Group's third report (submitted November 23, 2005). AttachmentA of the Order containsthe interim rules that the Commissionadopted. The interim rules, in part, establisheddefinitions for various terms consistentwith the REPS Act, compliancerequirements for electricity suppliers,generator eligibility, rules regarding the creationand tacking of RECs,and rules concerningthe recoveryof feesand costs. Order No. 13860(Januarv 26. 2006): Generally acceptedthe recommendationspresented in the RPS Working Group's report (submitted December 22, 2005) on comparable state certificatesand relatedissues. The Commissionpointed out that the use of the Tier I and Tier II eligibility matrices promotes a streamlined and simple process for the certification of renewableresources located outside of the District. consistentwith OrderNo. 13766. 34 Order No. 13899 (March 27. 2000: Respondedto Applications and/or Motions for Reconsideration and Clarification of Order No. 13840 filed by the Meadwestvaco Corporation,the PotomacElectric PowerCompany on behalf of the RPS Working Group, and jointly by Pepco Energy Services,Mirant Corporation, Washington Gas Energy Services, Inc., District of Columbia EnergyOffice, and Constellation. This Order, in part, amendedthe interim rules to indicate that retroactively created RECs must be tacked through GATS. In addition, with respect to the information to be included in the annual compliance report, the Commissionamended the interim rules to indicate that supplierspurchasing RECs solely via bundledproducts are exempt from including the total price paid for Tier I, Tier II, and Solar Energy Credits in their report. Order No. 14005 (Julv 24. 2000: Accepted in part and rejectedin part, recommendations containedin the RPS Working Group report addressingPhase II issues,submitted on March 24,2006. This Order further acceptedin part and rejectedin part recommendationscontained in supplementalcomments filed by the Office of the People'sCounsel and in reply comments filed jointly by the PotomacElectric Power Company,Pepco Energy Services,Inc., and the District of Columbia EnergyOffice. Order No. 14085 (October 13. 2006): Denied the Application for Reconsiderationof Order No. 14005frled by the MD-DC-VA SolarEnergy IndustriesAssociation. Order No. l4ll4 fNovernber 13. 2006): Accepted in part and rejected in part, recommendationscontained in the RPS Working Group report (September 15, 2006) regarding: (l) the use of engineering estimates to measure the output of small solar installations; (2) the District of Columbia's adoption of Behind-the-Meter rules and regulationsused in other Mid-Atlantic States;and (3) the RPS Working Group's responseto a hlpothetical questioninvolving renewableenergy credit creationthat was set forth in Order No. 13766. Order No. 14225 (March 2. 2001: Acceptedin part and rejectedin part recommendations containedin the RPS Working Group report, addressingissues identified in Order No. 14114, submiffedon December13, 2006. h particular,the Commissionamended the interim rules to addresscertain issuesregarding behind-the-metergeneration. OrderNo. 14697(January 10.2008): AdoptedChapter 29 of Title 15 District of Columbia Municipal Regulations("Final Rules"). The Final Rules became effective upon the publicationof the Notice of Final Rulemakingin the D.C. Register onJanuary18, 2008. Order No. 14782(April 10. 2008): Adopted the Electricity Supplier2007 ComplianceReport Form and associatedfiling instructionsfor the District's RPS Program. Electricity suppliers were directedto usethe form for the 2007 ComplianceReports due May 1, 2008. Order No. 14798(April 29. 2008): Directedon-site or behind-the-meter("BTM") generators, certified by the Commissionas eligible renewablegenerating facilities and requiredto file on- site or BTM generationreports under the Commission's rules, to file their reports with the Commission. 35 Order No. 14809(Mav 12. 2008): Directed the RPS Working Group to file, consistentwith the Commission'srules, an annualupdate to the Tier I andTier II eligibility matrices. OrderNo. 14885(Auzust 11.2008): Directedcertain electricity suppliers to file evidence with the Commissionthat each establishedGeneration Attribute Tracking System accounts and that the renewableenergy credits reported in their compliancereports have been properly retired. OrderNo. 15077(October 1.2008): DeniedWashington Gas Energy Services, Inc.'s request for a waiver of the 2007 compliance fee for solar renewable energy credits and directed the Company to file proof of payment of the 2007 compliancefee for solar renewableenergy credits. Order No. 15192 Gebruary 18. 2009): Directed the RPS Working Group to review the available infonnation regarding certain states and, if the RPS Working Group identifies any Tier I or Tier II renewable energy resourceswhose certification requirementsmay be comparableto the District's RPS program, to file an annual update. In identifying new resources,the Order noted that the RPS Working Group should be mindful of the fact that the Clean and Affordable Energy Act of 2008 has addedadditional certification requirementsfor certainsolar energyfacilities. Order No. 15233 (April 7. 2009): Adopted amendmentsto the RPS rules, an Affidavit of Environmental Compliance,and a revised Electricity Supplier Annual Compliance Report Form. Order No. 15561(September 28. 2009): Adopted amendmentsto RPS rules consistentwith the applicable sectionsof the Clean and Affordable Energy Act of 2008. In particular, the Commissionadded a new subsectiondetailing the requirementsfor meetingthe solar portion of the RPS requirement. In addition, the amendmentsraised the compliance fees for tier one and solar energy Renewable Energy Credit ("SREC") shortfalls as well as change the definition of solar energy. The amendments also required additional documentation for applications for certification of solar thermal systemsas District of Columbia renewable energyfacilities. Order No. 15581(October 21.2009): Denied Sol System'srequest to increasethe derate factor used in estimatingthe output of a solar photovoltaic ("PV") system. The deratefactor accountsfor the inefficiencies inherent in converting direct current ("DC"') producedby a solarPV systemto alternatingcurrent ("AC") usedin homesor businesses.Specifically, the deratefactor accountsfor the inefficiency of the solar panelsand inverter, as well as losses due to connectionsand wiring, amongother factors. Pursuantto the Commission'srules, solar RECs are created and tracked through the PJM Environmental lnformation Services, Inc.'s GenerationAttribute TrackingSystem ("PJM-EIS GATS"). PJM-EISGATS appliesa certain default derate factor utilizing P\,IWATTS, a performancecalculator for PV systems developedby the National RenewableEnergy Laboratory,which estimatesthe AC electricity producedby thesePV systems.These estimates in turn are usedto determinehow many solar 36 RECs individual photovoltaic systems generate. Sol Systerns offered no technical information of merit in supportof its request. Notice Reeardinsthe Submissionof Electricity Supolier Annual ComplianceReport for the District of Columbia'sRenewable Energv Portfolio Standard(March 23. 2010): Reminded electricity suppliersthat they may not usethe incinerationof solid wasteto meet more than 20 percentof the standardfor tier two renewablesources. In addition, startingJanuary 1,2013, suppliersare prohibited from using RECs derived from solid waste incinerationto meet any part of the Tier II standard. Notice Reeardinethe Submissionof Electricitv Supplier Annual ComplianceRepoft for the District of Columbia'sRenewable Enerey Portfolio Standard(March 18. 20ll): Reminded electricity suppliers that they are obligated to submit their annual renewable energy portfolio standardcompliance reports for calendaryear 2010 by May 2, 2}llae and that electricity suppliersshall meet the solar requirementby first exhaustingall opportunityto purchaseD.C. SRECsbefore purchasing non-D.C. SRECs. Order No. 16528 (September9. 20ll): Denied all applicationsfor certificationof solar energy facilities that were not located within the District, nor in locations served by a distribution feederserving the District, pendingbefore the Commissionon August L,20ll. Order No. 16529 (September9. 2011): Decertifiedall solar energyfacilities not located within the District or in locations servedby a distribution feeder serving the District, and certifiedby the Commissionbetween February I and August 1,2011, as well as any solar facilities with a capacitylarger than 5 MW regardlessof the date certified. In addition, the clarified that any solar renewable energy credits generated by solar energy facilities decertifiedpursuant to this Order cannotbe used to satisfy the solar portion of the District's RPS programfor the 2011 complianceyear nor any future complianceyear. Order No. 16680 (Januar.v12. 2012): Denied SolThermEnergy, LLC's applicationsfor recertificationof 15 facilities, arguing that the applicability sectionof the permanentversion of the legislation,the DistributedGeneration Amendment Act of 20ll ("DGAA" or the "Act"), exempts contracts for the purchase and sale of solar renewable energy credits ("SRECs") from the decertification provision of the Act. In its Order, the Commission indicated that rather than grandfathering-in SRECs and/or SREC conhacts, the DGAA effectively voided them after January31,2011. The Order mentionsthat the Council clarified the Act in both its emergencyand permanent versions and expresslyrequired the Commission to decertify any non-compliantfacility certified betweenFebruary 1,2011 and the effective dateof the EmergencyAct, August l,20ll. The Commissiondetermined that SolTherm's interpretationof the Act would frustratethe Council's intent to render SRECsfrom non-D.C. facilities unmarketabl*as SolTherm's facilities are located outside the District and are not in locations servedby a distribution feederserving the District. Therefore,the Commission concluded that it is statutorily precluded from recertifying them. In addition, SRECs 4e As May I fell on a Sunday,annual compliance reports were due the next businessday, Monday, }y'ray2, 2011. 37 extinguishedby operation of law when the Commissiondecertified the SolTherm facilities cannot be rekindled under a provision clearly intended to apply only to energy supply contracts. Order No. 16738 (March 15. 2012): Adopted the amended rules and revised annual compliancereport form publishedin the January 13,2012 Notice of ProposedRulemaking. The proposedamendments to the RPS rules include, amongother things, changespursuant to the DistributedGeneration Amendment Act of 2011. Order No. 16787 (May 25. 2012): Directed three alternative electricity suppliers- ConsolidatedEdison Solutions, Liberty Power, and Noble Americas Energy Solutions-to comply with statutory limit on the use of municipal solid waste to meet the RPS requirement for Tier II resources,based on their 2010 compliance reports. The three suppliers were directed to either show cause why this notification of non-complianceis unwarrantedor submit their respective payments for non-compliancepayable to the RenewableEnergy DevelopmentFund. OrderNo. 17062Gebruary 1.2013): Adoptedthe RPSWorking Group'sproposed Tier I and Tier II eligibility mafficesfor 2011 as modified. Order No. 17239 (September6. 2013): Denied the Virginia Living Museum's revised applicationto expandits existing solar generatingsystem as the secondarray is functionally separatefrom the existing array-being separatelymetered and located on two separate buildings, sharing no parts or components,and do not interact in any way. Given the information and argumentbefore the Commission,there was no basisupon which to conclude that the second array is anything other than a new facility that is disallowed under the Distributed Generation Amendment Act of 2011. as it is not in a location served bv a distribution feederserving the District of Columbia. OrderNo. 17349(Januqv 13.2014): Adoptedthe RPSWorking Group'sproposed Tier I and Tier II eligibility matrices submitted for 2013. The proposed eligibility matrices do not include solar energy or solid waste among the eligible resources for the streamlined certification process. In addition, the RPS Working Group accountedfor all nine (9) of the adjacentPJM states. Order No. 17350 (Januarv 13. 2014): Decertified two municipal solid waste facilities that were previously approved. After December31, 2012, the incineration of solid waste is no longer eligible to generateRECs to be used to satisfy the Tier II portion of the District's renewableenergy portfolio standard. The Commissionindicated that RECs from thesetwo facilities cannot be used to satisfy the Tier II portion of the RPS requirementfor the 2013 complianceyear, nor any future complianceyear. OrderNo. 17351(Januanr 10. 2014): Deniedthe SiliconRanch Corporation's application for certification of a solar energyfacility, with a capacityof least 30 MW, locatedin Georgia. In its Application, the Silicon Ranch Corporationindicated that it was seekingcertification of the solar energy facility as a Tier I out-of-stateresource, and it is not seekingcertification to 38 obtain SRECs. Basedon its review of the Commission'sRPS rules, the Applicant asserted that the District's solar carveout doesnot preventoutside of the District solar facilities like its own from being certified as a "generic" Tier I resource. By statute,Tier I renewablesources are clearly definedto meanone or more of the following types of energysources: solar, wind, qualifying biomass,methane from the decompositionof organicmaterials, geothermal, ocean, and fuel cells producing electricity from qualiffing biomassor methane. The Commission determinedthat since the statutory definition of a Tier I renewablesource is based on the sourceused to produceenergy, a Tier I renewablesource cannot, therefore, be "generic." In addition, the applicant did not provide any supporting legal authority for the creation of a "generic" Tier I source. Nor does the statute authorizethe Commissionto certi$ a solar facility outsideof the District which is not in a location servedby a distribution feederserving the District of Columbia andwhich is larger than 5 MW in capacity. Order No. 17379 Gebruqv 12. 2014): Directed the Potomac Electric Power Company ("Pepco") to incorporatethe changesset out in this Order in its future Annual Interconnection Reports. Order No. 17393 (Februarv 20. 2014): Denied the application for certification of the Welch/IVlolloy Residence's Solar Energy Facility as a Renewable Energy Standards GeneratingFacility becausethe solar energy facility is not locatedwithin the District or in a location servedby a distribution feederserving the District, pursuantto the DGAA. Order No. 17673(October 24. 2014): Adopted a modified version of the NOPR publishedin the D.C. Registeron June27,2014. The frling deadlinefor RPS compliancereports and fees in Sections290L7 and290l.9 of the RPS Ruleswas moved from May I to April 1. Order No. 17794 Gebruar.v4. 201fl: Addressedcomments from interestedpersons and describedchanges to the NOPR publishedon September12,2014 amendingChapter 9, Rules and RegulationsGoverning Net Energy Metering ("NEM"), to implementthose provisions of the Community RenewableEnergy Amendment Act of 2013 ("CREA") regarding the community net metering program. A revised NOPR with the incorporated changeswas publishedin the D.C. Registeron January30, 2015 for commentby interestedpersons. Order No. 17862 (Aeril 24. 2015): Adopted revised rules and regulationsgoverning Net Energy Metering ("NEM') to implement those provisions of the Community Renewable Energy Amendment Act of 2013 ("CREA") which establishthe community net metering program. Order No. 17863 (April 24. 2015): Adopted amendmentsto Chapter 41, "District of Columbia StandardOffer Service ['SOS'] Rules," which were made to implementthose provisionsof the CommunityRenewable Energy AmendmentAct of 2013 ("CREA") that affect SOS. OrderNo. 18050(December ll. 2015): Approvedthe PotomacElectric Power Company's ("Pepco")Community Renewable Energy Facilities Documents ("CREF Documents")filed, pursuant to Chapter 9 of Title 15 of the District of Columbia Municipal Regulations 39 ('DCMR") as well as the "Procedural Manual for Implementationand Administration of Community RenewableEnergy Facilities" (*CREF ProceduralManual"). The Commission directed Pepco to amendthe CREF Documents and the proposedCREF ProceduralManual in accordancewith the directives of this Order. Order No. 18135(March 3. 2016): Grantedthe motion of PotomacElectric Power Company ("Pepco") to reconsiderthe Commission'sdecision in Order No. 18050. Pepcowas directed to modiff the CREF Conhact consiste,ntwith this Order. 40 Attachment 3 Map of the Certified Solar Energy Systemsin the District of Columbia 4l ' zeF w 7oa **lr, l 4^ +^ Takoma "', p' *-- i'X *; , I a j Prt'--- ,t''j f {r TheRenewable Energy i C..d("o* Crl lg ". ;1 PortfolioStandard ('RPS") Act [r.li -..-- -ii establisheda manimum percentageof Districtelectrlcity . providers'supplythat mustbe derivedfrom renewableenergy 30urces. lmry{, :dbc' a tr f , -.$s- r'a!'i-us'50'G ) rd -r.trE a r! . C ^ *..t'- lt;;:H c@Y to/ -#. ;-- . F---l St#"rH ',It,- r. , ung : I l Mdt I NGTON clrd6 PIi DC SOLAR GAPACITY la t PROGRESS & GOATS a , trt\ fuo6r ! IE t {t Scillud t> ta t' .t' ;rcoily i I i crnoty r I : rgzlrw i : lfhu flgurcs w ment os ol Aprrl 1, 2016 ontt des lmlsde etol-ilote tmllhlesl t L;6kt 41 1 ar Faciliticsby Year ,l t sl ,. a, t o ilctao Ectco occ2err ogczolt otctott oQcloil 0cctr6 rtlilra Sublic 9ietbitt Gommissionof tte Distrid of Golumbiu 1325G Street,N.W., Eft trloor Washington,D.C. 20005 (202)626-srm www.dcDsc.org BettyAnn Kane Chairman May2,2016 VIAHAND DELIVERY NyashaSmith Secretaryto the Council Councilof the Districtof Columbia 1350Pennsylvania Avenue, NW Washington,D.C. 20004 Re: Reporton the RenewableEnergy Portfolio Standard for Compliance Year2015 DearMs. Smith: Attachedis the Public Service Commissionof the Districtof Columbia's ("Commission")Report on the RenewableEnergy Portfolio Standard, which is filed in accordancewith S 34-1439of the Districtof ColumbiaOfficial Code. Specifically,this sectionrequires the Commissionto file a reportwith the Councilon or beforeMay 1 of everyyear on the statusof implementationof the RenewableEnergy Portfolio Standard Act, including:the availabilityof tier one renewableresources; certification of the numberof creditsgenerated by the utilitiesmeeting the requirementsof S 34-1432;and anyother such information as the Councilshall consider necessary. Thankyou. lf you haveany questions,please do not hesitateto contactme. Sincerely, Attachment cc: The HonorableJoanne Doddy Fort, Commissioner, Public Seruice Commission The HonorableWillie Phillips, Commissioner, Public Service Commission lFubtic9iefiiw Gommissionof tle Digttid of Golumbis 1325G Street,N.W.,8ft Floor Washington,D.C. 20005 (202)626-sr00 www.dcpsc.org Betty Ann Kane Chairman May2, 2016 VIAHAND DELIVERY The HonorablePhil Mendelson Councilof the Districtof Columbia 1350Pennsylvania Avenue, NW Washington,D.C. 20004 Re: Reporton the RenewableEnergy Portfolio Standardfor Compliance Year2015 DearChairman Mendelson: Attachedis the Public Service Commissionof the Districtof Columbia's ("Commission")Report on the RenewableEnergy Portfolio Standard, which is filed in accordancewith S 34-1439of the Districtof ColumbiaOfficial Code. Specifically,this sectionrequires the Commissionto file a reportwith the Councilon or beforeMay 1"' of everyyear on the statusof implementationof the RenewableEnergy Portfolio Standard Act, including:the availabilityof tier one renewableresources; certification of the numberof creditsgenerated by the utilitiesmeeting the requirementsof $ 34-1432;and anyother such information as the Councilshall consider necessary. Thankyou. lf youhave any questions, please do nothesitate to contactme. Sincerely, )/ ' '--1 ,/r bttr v-/, rLn*Y l- | BettyAnn Kane Attachment cc: TheHonorable Joanne Doddy Fort, Commissioner, Public Service Commission The HonorableWillie Phillips, Commissioner, Public Service Commission Subtic9lettitt Goruniggionof tbeDigtrid of Golumbis 1325G Street,N.W.,8e Floor Washington,D.C. 20005 (202)626-sr00 www.dcpsc.org BettyAnn Kane Chairman May2,2016 VIAHAND DELIVERY The HonorableKenyan McDuffie Councilof the Districtof Columbia 1350Pennsylvania Avenue, NW Washington,D.C. 2OOO4 Re: Reporton the RenewableEnergy Portfolio Standardfor Compliance Year 2015 DearCouncilmember McDuffie: Attachedis the Public Service Commissionof the Districtof Columbia's ("Commission")Report on the RenewableEnergy Portfolio Standard, which is filed in accordancewith S 34-1439of the Districtof ColumbiaOfficial Code. Specifically,this sectionrequires the Commissionto filea repoftwith the Councilon or beforeMay 1st of everyyear on the statusof implementationof the RenewableEnergy Portfolio Standard Act, including:the availabilityof tier one renewableresources; certification of the numberof creditsgenerated by the utilitiesmeeting the requirementsof S 34-1432;and anyother such information as the Councilshall consider necessary. Thankyou. lf youhave any questions, please do nothesitate to contactme. Sincerely, BettyWLlc-*-Ann Kane Attachment cc: TheHonorable Joanne Doddy Fort, Commissioner, Public Seruice Commission TheHonorable Willie Phillips, Commissioner, Public Service Commission Subticbettin Gommitsionof tbeDigtrid of Golumbie 1325G Street,N.W., 8fr Floor Washington,D.C. 20005 (202)626-sr00 www.dcpsc.org BettyAnn Kane Chairman May2,2016 VIAHAND DELIVERY The HonorableAnita Bonds Councilof the Districtof Columbia 1350Pennsylvania Avenue, NW Washington,D.C. 20004 Re: Reporton the RenewableEnergy Portfolio Standardfor Compliance Year 2015 DearCouncilmember Bonds: Attachedis the Public Service Commissionof the Districtof Columbia's ("Commission")Report on the RenewableEnergy Portfolio Standard, which is filed in accordancewith S 34-1439of the Districtof ColumbiaOfficial Code. Specifically,this sectionrequires the Commissionto filea reportwith the Councilon or beforeMay 1"'of everyyear on the statusof implementationof the RenewableEnergy Portfolio Standard Act, including:the availabilityof tier one renewableresources; certification of the numberof creditsgenerated by the utilitiesmeeting the requirementsof $ 34-1432;and anyother such information as the Councilshall consider necessary. Thankyou. lf youhave any questions, please do nothesitate to contactme. -->Sincerely, */aa c-- t-ltfr( v- - lL I BettyAnn Kane Attachment cc: The HonorableJoanne Doddy Fort, Commissioner, Public Seruice Commission The HonorableWillie Phillips, Commissioner, Public Service Commission Subtic9iettliw Gommisgion of tUeDigtrid of Golumbia 1325G Street,N.W.,8ft Floor Washington,D.C. 20005 (202)626-sr00 www.dcpsc.org BettyAnn Kane Chairman May2,2016 VIA HANDDELIVERY The HonorableDavid Grosso Gouncilof the Districtof Columbia 1350Pennsylvania Avenue, NW Washington,D.C. 20004 Re: Reporton the RenewableEnergy Portfolio Standardfor Compliance Year 2015 DearCouncilmember Grosso: Attachedis the Public Service Commissionof the Districtof Columbia's ("Commission")Report on the RenewableEnergy Portfolio Standard, which is filed in accordancewith S 34-1439of the Districtof ColumbiaOfficial Code. Specifically,this sectionrequires the Commissionto filea reportwith the Councilon or beforeMay 1"'of everyyear on the statusof implementationof the RenewableEnergy Portfolio Standard Act, including:the availabilityof tier one renewableresources; ceftification of the numberof creditsgenerated by the utilitiesmeeting the requirementsof $ 34-1432;and anyother such information as the Councilshall consider necessary. Thankyou. lf youhave any questions, please do nothesitate to contactme. Sincerely, ---7= n -1 ./ ,-""[V.v6"tt-/- l( " BettyAnn Kane Attachment cc: The HonorableJoanne Doddy Fort, Commissioner, Public Service Commission The HonorableWillie Phillips, Commissioner, Public Service Commission Subtir 9refiiu Gommiggionof OeEistrid ot GolumbiE 1325G Street, N.Wr 8fr Floor Washington,D.C. 20005 (202)626-sr00 www.dcpsc.org BettyAnn Kane Chairman May2,2016 VIA HANDDELIVERY The HonorableMary Cheh Gouncilof the Districtof Columbia 1350Pennsylvania Avenue, NW Washington,D.C. 20004 Re: Reporton the RenewableEnergy Portfolio Standardfor Compliance Year 2015 DearCouncilmember Cheh : Attachedis the Public Service Commissionof the Districtof Columbia's ("Commission")Report on the RenewableEnergy Portfolio Standard, which is filed in accordancewith S 34-1439of the Districtof ColumbiaOfficial Code. Specifically,this sectionrequires the Commissionto filea reportwith the Councilon or beforeMay 1sr of everyyear on the statusof implementationof the RenewableEnergy Portfolio Standard Act, including:the availabilityof tier one renewableresources; certification of the numberof creditsgenerated by the utilitiesmeeting the requirementsof $ 34-1432;and anyother such information as the Councilshall consider necessary. Thankyou. lf youhave any questions, please do nothesitate to contactme. Sincerely, Attachment cc: The HonorableJoanne Doddy Foft, Commissioner, Public Service Commission The HonorableWillie Phillips, Commissioner, Public Service Commission Sub[ir 9rettiittGommission of tte Eidftid of GolumbiE 1325G Street,N.W.,8fr Floor Washington,D.C. 20005 (202)626-sr00 www.dcpsc.org BettyAnn Kane Chairman May2,2016 VIAHAND DELIVERY The HonorableJack Evans Councilof the Districtof Columbia 1350Pennsylvania Avenue, NW Washington,D.C. 20004 Re: Reporton the RenewableEnergy Portfolio Standardfor Compliance Year 2015 DearCouncilmember Evans: Attachedis the Public SeruiceCommission of the Districtof Columbia's ("Commission")Report on the RenewableEnergy Portfolio Standard, which is filed in accordancewith S 34-1439of the Districtof ColumbiaOfficial Code. Specifically,this sectionrequires the Commissionto filea reportwith the Councilon or beforeMay 1"t of everyyear on the statusof implementationof the RenewableEnergy Portfolio Standard Act, including:the availabilityof tier one renewableresources; certification of the numberof creditsgenerated by the utilitiesmeeting the requirementsof $ 34-1432;and anyother such information as the Councilshall consider necessary. Thankyou. lf youhave any questions, please do nothesitate to contactme. Sincerely, 1 r ef'- Br AnnKane Attachment cc: The HonorableJoanne Doddy Fort, Commissioner, Public Service Commission TheHonorable Willie Phillips, Commissioner, Public Service Commission Subticbefiiu Gommiggionof tbeBistrid of Golumbie 1325G Street,N.W.,8fr Floor Washington,D.C. 20005 (202)626-sr00 www.dcpsc.org BettyAnn Kane Chairman May2,2016 VIAHAND DELIVERY The HonorableBrianne Nadeau Councilof the Districtof Columbia 1350Pennsylvania Avenue, NW Washington,D.C. 20004 Re: Reporton the RenewableEnergy Portfolio Standardfor Compliance Year2015 DearCouncilmember Nadeau : Attachedis the Public Service Commissionof the Districtof Columbia's ("Commission")Report on the RenewableEnergy Portfolio Standard, which is filed in accordancewith S 34-1439of the Districtof ColumbiaOfficial Code. Specifically,this sectionrequires the Commissionto filea reportwith the Councilon or beforeMay 1"tof everyyear on the statusof implementationof the RenewableEnergy Portfolio Standard Act, including:the availabilityof tier one renewableresources; certification of the numberof creditsgenerated by the utilitiesmeeting the requirementsof $ 34-1432;and anyother such information as the Councilshall consider necessary. Thankyou. lf youhave any questions, please do nothesitate to contactme. Sincerely, ffir*- BettyAnn Kane Attachment cc: The HonorableJoanne Doddy Fort, Commissioner, Public Service Commission The HonorableWillie Phillips, Commissioner, Public Service Commission Subtit 9rwnilcGommiggion of tbeDistrid of GolumbiE 1325G Street,N.W.,8ft Floor Washington,D.C. 20005 (202\626-sr0o www.dcpsc.org BettyAnn Kane Chairman May2,2016 VIAHAND DELIVERY The HonorableElissa Silverman Councilof the Districtof Columbia 1350Pennsylvania Avenue, NW Washington,D.C. 20004 Re: Reporton the RenewableEnergy Portfolio Standardfor Compliance Year 2015 DearCouncilmember Silverman: Attachedis the Public Service Commissionof the Districtof Columbia's ("Commission")Report on the RenewableEnergy Portfolio Standard, which is filed in accordancewith S 34-1439of the Districtof ColumbiaOfficial Code. Specifically,this sectionrequires the Commissionto filea reportwith the Councilon or beforeMay 1"t of everyyear on the statusof implementationof the RenewableEnergy Portfolio Standard Act, including:the availabilityof tier one renewableresources; certification of the numberof creditsgenerated by the utilitiesmeeting the requirementsof $ 34-1432;and anyother such information as the Councilshall consider necessary. Thankyou. lf youhave any questions, please do nothesitate to contactme. Sincerely, Attachment cc: The HonorableJoanne Doddy Fort, Commissioner, Public Seruice Commission The HonorableWillie Phillips, Commissioner, Public Service Commission lFublit 9iefiin Gommiggionof tle Distrid of Columbig 1325G Street,N.W.,8ft Floor Washington,D.C. 20005 (202) 626-5100 www.dcosc.org Betty Ann Kane Chairman May2,2016 VIA HANDDELIVERY The HonorableVincent Orange Councilof the Districtof Columbia 1350Pennsylvania Avenue, NW Washington,D.C. 20004 Re: Reporton the RenewableEnergy Portfolio Standardfor Compliance Year2015 DearCouncilmember Orange: Attachedis the Public Service Commisslonof the Districtof Columbia's ("Commission")Report on the RenewableEnergy Portfolio Standard, which is filed in accordancewith S 34-1439of the Districtof ColumbiaOfficial Code. Specifically,this sectionrequires the Commissionto file a reportwith the Councilon or beforeMay 1"'of everyyear on the statusof implementationof the RenewableEnergy Portfolio Standard Act, including:the availabilityof tier one renewableresources; certification of the numberof creditsgenerated by the utilitiesmeeting the requirementsof $ 34-1432;and anyother such information as the Councilshall consider necessary. Thankyou. lf youhave any questions, please do nothesitate to contactme. Sincerely, BettyAnn Kane Attachment cc: The HonorableJoanne Doddy Fort, Commissioner, Public Service Commission TheHonorable Willie Phillips, Commissioner, Public Service Commission Sub[it 9iefrircGommission oftUe Distrid of Golumbiu 1325G Street,N.W., Eft Floor Washington,D.C. 20005 (202)626-sr00 www.dcpsc.org BettyAnn Kane Chairman May2,2016 VIAHAND DELIVERY The HonorableBrandon Todd Councilof the Districtof Columbia 1350Pennsylvania Avenue, NW Washington,D.C. 2OOO4 Re: Reporton the RenewableEnergy Portfolio Standardfor Compliance Year2015 DearCouncilmember Todd: Attachedis the Public Service Commissionof the Districtof Columbia's ("Commission")Report on the RenewableEnergy Portfolio Standard, which is filed in accordancewith S 34-1439of the Districtof ColumbiaOfficial Code. Specifically,this sectionrequires the Commissionto filea reportwith the Councilon or beforeMay 1st of everyyear on the statusof implementationof the RenewableEnergy Portfolio Standard Act, including:the availabilityof tier one renewableresources; certification of the numberof creditsgenerated by the utilitiesmeeting the requirementsof S 34-1432;and anyother such information as the Councilshall consider necessary. Thankyou. lf youhave any questions, please do nothesitate to contactme. Sincerely,14tr-7/* BettyAnn Kane Attachment cc: The HonorableJoanne Doddy Fort, Commissioner, Public Service Commission The HonorableWillie Phillips, Commissioner, Public Seruice Commission Sublit 9retllittGommisgion of tbeDistrid of GolumbiE 1325G Street,N.W.,8e Floor Washington,D.C. 20005 (202)626-SrW www.dcpsc.org Betty Ann Kane Chairman May2,2016 VIAHAND DELIVERY The HonorableCharles Allen Gouncilof the Districtof Columbia 1350Pennsylvania Avenue, NW Washington,D.C. 20004 Re: Reporton the RenewableEnergy Portfolio Standardfor Compliance Year2015 DearCouncilmember Allen : Attached is the Public Service Commissionof the District of Columbia's ("Commission")Report on the RenewableEnergy Portfolio Standard, which is filed in accordancewith S 34-1439of the Districtof ColumbiaOtficial Code. Specifically,this sectionrequires the Commissionto filea reportwith the Councilon or beforeMay 1s' of everyyear on the statusof implementationof the RenewableEnergy Portfolio Standard Act, including:the availabilityof tier one renewableresources; certification of the numberof creditsgenerated by the utilitiesmeeting the requirementsof S 34-1432;and anyother such information as the Councilshall consider necessary. Thankyou. lf youhave any questions, please do nothesitate to contactme. BettyAnn Kane Attachment cc: TheHonorable Joanne Doddy Fort, Commissioner, Public Seruice Commission . The HonorableWillie Phillips, Commissioner, Public Service Commission Sublic 9letbitt Gommistionof tbeDigtrid of Golumbie 1325G Street,N.W.,8tr Floor Washington,D.C. 2m05 (202)626-srm www.dcpsc.org BettyAnn Kane Chairman May2,2016 VIA HANDDELIVERY The HonorableYvette Alexander Councilof the Districtof Columbia 1350Pennsylvania Avenue, NW Washington,D.C. 20004 Re: Reporton the RenewableEnergy Portfolio Standardfor Compliance Year2015 DearCouncilmember Alexander: Attachedis the Public Service Commissionof the Districtof Columbia's ("Commission")Report on the RenewableEnergy Portfolio Standard, which is filed in accordancewith S 34-1439of the Districtof ColumbiaOfficial Code. Specifically,!,his sectionrequires the Commissionto filea reportwith the Councilon or beforeMay 1"' of everyyear on the statusof implementationof the RenewableEnergy Portfolio Standard Act, including:the availabilityof tier one renewableresources; certification of the numberof creditsgenerated by the utilitiesmeeting the requirementsof $ 34-1432;and anyother such information as the Councilshall consider necessary. Thankyou. lf youhave any questions, please do nothesitate to contactme. Sincerely, (- WL1BettyAnn Kane Attachment cc: The HonorableJoanne Doddy Fort, Commissioner, Public Service Commission TheHonorable Willie Phillips, Commissioner, Public Seruice Commission Sub[ir 9rtrfiu Gormmissionof tbe Digtrid of GolumbiE 1325G Street,N.W.,8ft trloor Washington,D.C. 20005 (202)626-srm www.dcpsc.org BetE Ann Kane Chairman May2,2016 VIAHAND DELIVERY The HonorableLaRuby May Councilof the Districtof Columbia 1350Pennsylvania Avenue, NW Washington,D.C. 20004 Re: Reporton the RenewableEnergy Portfolio Standardfor Compliance Year2015 DearCouncilmember May: Attachedis the Public Service Commissionof the Districtof Columbia's ("Commission")Report on the RenewableEnergy Portfolio Standard, which is filed in accordancewith S 34-1439of the Districtof ColumbiaOtficial Code. Specifically,this sectionrequires the Commissionto filea reportwith the Councilon or beforeMay 1"'of everyyear on the statusof implementationof the RenewableEnergy Portfolio Standard Act, including:the availabilityof tier one renewableresources; certification of the numberof creditsgenerated by the utilitiesmeeting the requirementsof S 34-1432;and anyother such information as the Councilshall consider necessary. Thankyou. lf youhave any questions, please do nothesitate to contactme. Sincerely,ptTLlz*- BettyAnn Kane Attachment cc: The HonorableJoanne Doddy Fort, Commissioner, Public Seruice Commission The HonorableWillie Phillips, Commissioner, Public Service Commission