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Large Texas Customers Seek Creation Of Energy Attribute Certificate Trading Program At ERCOT (Nuclear, Storage, "Low Carbon" Gas, More)
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The Texas Energy Buyers Alliance (TEBA) has submitted to ERCOT a Nodal Protocol Revision Request to implement an Energy Attribute Certificates (EACs) program, with the request designated as NPRR 1264
Under the NPRR, EACs, "can be earned by any generator, regardless of fuel type," TEBA said in a narrative describing the NPRR
RECs would become a subcategory of EACs
TEBA says that the EAC program would allow for the trading of nuclear, battery storage, and similar attributes
Under a proposed field for the EAC tracking, borrowing from the current REC table, NPRR 1264 proposes that, under "Type of Energy Resource", the following may be indicated: "Solar, wind, biomass, tidal, geothermal, hydro, landfill gas, other, nuclear, energy storage, low carbon gas, etc."
Among other things, TEBA says that EACs, "will provide a new revenue source for generators and enable additional innovation in retail product offerings."
EACs would specifically be defined as, "A tradable instrument that represents all of the attributes associated with one MWh of production from a generator that registers to participate in the program. An EAC may be fractional. EACs do not include any energy, capacity, reliability, or other power attributes used to provide electricity services, nor liabilities associated with such generation, nor any tax credits, depreciation allowances or third-party subsidies of any kind."
As under the current the REC program, EACs would have a life of 3 years
NPRR 1264 notes that, "The production of an EAC by an Energy Storage Resource (ESR) is no guarantee of the type of energy used to initially charge it and the buyer of such a certificate is solely responsible for its use," though the NPRR states that a third-party certification program described in the NPRR is, "designed to address this."
"To add value to the EAC program, this NPRR creates a new category of participants -- third-party certification programs. EAC Account Holders may use these third parties to provide documentation to ERCOT and other Market Participants about how they charged energy storage devices, provided fuel for generators, or met certain operational characteristics to be determined by Market Participants," a narrative describing the NPRR states
As proposed, a generator participating in the EAC program may optionally choose to have their EACs issued on an hourly basis instead of monthly.
In addition to the NPRR, TEBA proposes related changes to various market and operating guides, including the Retail Market Guide
The NPRR comes as the Texas RPS ends on September 1, 2025
TEBA averred that the PUC's RPS rule, as the REC tracking program run by ERCOT becomes voluntary, allows ERCOT to add additional attributes to, "Renewable Energy Certificates".
TEBA said that the NPRR, "implements that allowance."
Although TEBA in a narrative did not cite a specific subsection of the rule (citing only Subst. R. 25.173), §25.173 states in one subsection that, "The program administrator [ERCOT] may assign additional attributes to RECs, such as more precise
REC generation timestamps, to allow buyers to distinguish between RECs."
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December 19, 2024
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Copyright 2024 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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