How does a project qualify to have collateral withheld from the first REC payment?

In order to have collateral withheld from the first REC payment rather than having to post collateral in the form of cash or a letter of credit, a Designated System must:

  1. Be interconnected and generating electricity as of the date of ICC approval (Trade Date);
  2. Have a standing order initiated with the contracting utility in PJM-GATS or M-RETS within 30 business days of the Trade Date;
  3. Be Part II Verified by the Program Administrator, as evidenced by the issuance of Schedule B to Exhibit A, within 30 business days of the Trade Date;
    • The Approved Vendor must submit Part II of a Designated System’s project application at least four weeks prior to the collateral due date to allow the Program Administrator sufficient time to review the submission and issue Schedule B to Exhibit A. Please see this FAQ for additional detail.
  4. Have a request made via email by the Approved Vendor to the contracting utility as soon as possible after its receipt of Schedule B and no later than 30 business days of the Trade Date that the utility withholds collateral from the first REC payment. The email must include the application ID, batch ID, contract ID, Trade Date, interconnection date, and Approved Vendor name.

Email requests for collateral withholding should be directed to the following contacts for a project’s contracting utility, which may be different from the interconnecting utility:

Once the contracting utility verifies that a Designated System meets the criteria to have collateral withheld from the first REC payment:

  • The contracting utility will confirm via email to the Approved Vendor that the Designated System qualifies for collateral withholding.
  • Once it receives the Program Administrator’s invoice during the quarterly invoicing window, the Approved Vendor will append to the Program Administrator’s invoice a line item for each Designated System from which collateral will be withheld, noting the collateral amount from the Schedule B for each Designated System.


System ID xxx – collateral withholding $xx,xxx.xx
  • The contracting utility will review the Approved Vendor’s invoice and provide any feedback and/or corrections.
  • Once the contracting utility verifies that the Approved Vendor’s invoice is correct, it will provide payment in accordance with the terms of the REC contract.

Please note that the invoices and Quarterly Netting Statements originally generated by the Program Administrator at the beginning of each quarterly invoicing window represent the Maximum Allowable Payment for the Quarterly Period. The amount contained on that initial invoice does not reflect any collateral withheld under modified Section 4.3(a) of the Master REC Agreement of the REC Contract. In the case of an individual Designated System’s Collateral Requirement being withheld from its first REC payment, the actual amount due will be lower than that listed on the original invoice.