Section 6.17 of the Revised Long-Term Plan describes an annual report requirement for each Approved Vendor:
On an annual basis, each Approved Vendor is required submit an Annual Report of the contracts and systems in its portfolio. The Annual Report serves as the basis for verifying that RECs from projects are being delivered to the applicable utility, and, absent corrective actions taken by the Approved Vendor, will be used to determine what actions should be taken by the utilities to enforce the contractual requirements that RECs are delivered, including, but not limited to, drawing on collateral. Additionally, the Annual Report will be used by the Agency to consider the ongoing eligibility of an Approved Vendor to continue participation in the program.
Submission of the annual report takes place via the ABP portal and is now live.
Approved Vendors are required to submit the annual report no later than July 15, 2020 for all ABP activity from January 30, 2019 (Program start date) through May 31, 2020.
Please note that failure to submit an annual report may be considered an Event of Default under the REC contract and could affect an Approved Vendor’s ongoing status in the Program. Approved Vendors will have the chance to cure deficiencies by October 13, 2020 under Section 10(c) of the REC contract; failure to cure any deficiencies prior to the October 13th deadline may also be considered an Event of Default.
Please note that per Section 6(d) of the REC contract, collateral drawdowns take place only after a project has been Energized for at least three full energy years.
The annual report includes the following items for all projects:
- RECs delivered by each of the systems in the portfolio
- Status of all systems that have been approved, but not yet energized, including any extensions requested and granted (Note that extension requests cannot be made through this annual report. They must be made pursuant to guidance issued by the IPA on May 5, 2020.)
- Energized systems that have not delivered RECs in the year
- Balance of collateral held by each utility
- A summary of requests for REC obligations reductions due to force majeure events
- A summary of requests for REC obligations, suspensions, reductions, or eliminations due to force majeure events
- Information on consumer complaints received
- Other information related to ongoing program participation, including use of graduates of job training programs and other information related to increasing the diversity of the solar workforce
The last item above is currently the topic of a stakeholder comment process; as a result, job training information likely will be collected separately from the rest of the annual report data after the stakeholder comment process concludes.
The annual report also includes the following items for community solar projects only:
- Percentage of each system subscribed on a capacity basis
- The number and type of subscribers (e.g., residential, small commercial, large commercial/industrial), including capacity allocated to each type
- Subscriber turn-over rates
Rather than require the Approved Vendor to compile much of the information for the Annual Report independently, many of the items Approved Vendors are required to report on will be provided by the Program Administrator. For these items, the Approved Vendor will only need to either confirm the accuracy of the data or note any discrepancies in the data set provided.
Please reach out to the Program Administrator at (877) 783-1820 or [email protected] with any questions regarding the annual reporting process.
