Electric Service Providers will make transfers to the Compliance Sub-Account to mirror and support their annual compliance filing with the Commission. Credits in this sub-account will remain in Active status until the Compliance Sub-Account has been reviewed and approved by the Commission.
A Michigan Electric Service Provider (ERP) Account is the only type of Account that can Retire Credits for compliance with PA295. However, other account types can make Voluntary Retirements
Compliance Sub-Accounts are automatically created annually in MIRECS and a separate Compliance Sub-Account will be created for each compliance year.
Following the creation of the Compliance Sub-Account, Electric Service Providers can proceed to transfer Credits to the Compliance Sub-Account(s). Credits can be transferred into the Compliance Sub-Account and from the Compliance Sub-Account to other Sub-Accounts until the Account is ‘submitted’ to the Commission (see #4 below).
The exception to this is for Credits for which PA 295 eligibility expires prior to submission of the Compliance Sub-Account. For these Credits, the following applies:
- The Credits must be transferred to the Compliance Sub-Account prior to the expiration of the PA 295 eligibility.
- The Credits can only be transferred to a Compliance Sub-Account for Compliance Year that is equal to or prior to the year in which the PA 295 eligibility will expire.
- If the Credits are in the Compliance Sub-Account before the PA 295 eligibility expires, they will retain the eligibility for the specific Compliance Year.
- After the expiration date has been passed the Credits can no longer be transferred to or from a Compliance Sub-Account.
Transferring Credits to a Compliance Sub-Account
To transfer active Renewable Energy Credits (RECs) to a Sub-Account, please take the following steps:
- In the Account Dashboard, locate the Account Status module.
- Under the Account Status module, Click on an ‘Active’ RECs link.
Note: User can also Click other REC positions to access transfer screen.
- In the Active credit screen, select the batch(es) of RECs that you wish to retire.
- Clicking the top box in column A will select all RECS on the visible page.
- Adjust transfer quantity as needed for each row selected.
- Review the “Total Quantity” to transfer and Click [Batch Transfer].
Summary of Steps in Credit’s Transfer Screen (Steps 3, 4, and 5):
- The user is then taken to the “Transfer Credits” screen to finalize where the RECs will be transferred.
- Click the “Compliance” radio button and choose the compliance subaccount for the appropriate compliance year.
- Verify all details of the transfer are accurate and Click [Submit] to complete the Compliance retirement of Credits.
Note: User may need to continue transferring Credits until the annual requirement is met.
Submit Annual Compliance Filing to Michigan Public Services Commission (MPSC)
To satisfy the requirements of PA 295, Michigan Electronic Service Providers are required to transfer eligible credits into their Annual Compliance Subaccount and submit, through MIRECS, the completed subaccount to the Michigan Public Service Commission for approval.
Note: Submitting the Compliance Sub-account for Commission review will lock the Credits in place.
To submit Compliance filing for approval, please complete the following steps:
- Log into MIRECS.
- Locate the “Open Sub-Account” module and select the hyperlinked ‘Sub-Account Name’ to access the relevant Compliance (Active) Sub-Account.
- From the Edit Sub-Account screen, Click on the ‘Compliance Report’ link
- In the Compliance Report, Click on the [Submit] button.
Note: The Compliance Report featured above, will display the quantity achieved and quantity still needed to meet the annual requirement. The report will also show how many of the Credits are Renewable Energy Credits, Incentive Renewable Energy Credits, Advanced Cleaner Energy Credits (and whether the ACE Credits are from a plasma facility or not), and whether the Credits are from project owned by the Electric Service Provider.
MPSC Review of Compliance Filing
The Commission will receive an automatic notification that a report has been submitted for their review. After their review, the Commission can elect to either ‘approve’ or ‘reject’ the Compliance Sub-account. Approval will result in the Credits being Retired permanently in the Compliance Sub-account associated with the given compliance year. Rejection will reopen the Compliance Sub-Account to allow the Account Holder to amend the Compliance Sub-account with the required Credits after which they can resubmit the Sub-account for Commission review. Status of the Compliance Sub-Account can be accessed via the Compliance Reports