Issuing IRECs based on REC Imports:
Notes on Incentive RECs from Imports:
- IRECS will only be issued for the generation of the RECs that have been imported into MIRECS.
- The IRECs associated with imported RECs will be issued to the REC owner.
- The Project owner is still required to fill out the affidavits and report on-peak generation but the IRECs are issued in the account of the REC owner.
- Fractional IRECS are rounded down and not carried over.
- The remaining fractional amount will be tracked in an import report called Import Fractional Credits.
The IRECS created based on REC Imports may have a fraction associated with them. When this occurs, the fractional IRECS will be rounded down, and the remaining fractional amount will be tracked in an import report called Import Fractional Credits.
Please note, that On-Peak generation is required for the applicable IRECS to be issued with the imports:
- If On-peak Generation is not entered -by the import project verifier - prior to the time the Imports are accepted by MIRECS admin, then the project will need to be re-approved by the MIRECS Admin After the generation is entered by the verifier.
Exporting RECs Associated with Incentive RECs:
Based on previous decisions by the Michigan Commission as well as the rules of other tracking systems RECs can only be exported if an adjustment is made to cancel out a proportional amount of RECs and/or IRECs that were created in excess of the 1 MWh to 1 REC definition of a whole credit.
Any process for handling exports must consider the fact that IRECs and RECs may be owned by different parties in MIRECS and that the ratio of IRECs issued for a given project is not constant from month to month. The approach must also recognize that in the eyes of the Michigan Commission, an IREC is equal to a REC for annual portfolio filing purposes (i.e. they can be substituted for each other with no limits). The general approach is that if a purchaser of RECs exports them they are reduced based on the MWh-to-REC ratio from the associated REC Facility and vintage. This will work in the following way:
- The table below shows the process for a variety of different ratios:
|
Scenario |
MWh of Generation |
MIRECS RECs Issued |
MIRECS IRECs Issued |
MWh-to-RECs Ratio |
RECs selected for export from MIRECS |
Import RECs issued in PJM |
|
1 |
500 |
500 |
125 |
0.8 |
500 |
400 |
|
2 |
1000 |
1000 |
250 |
0.8 |
1000 |
800 |
|
3 |
500 |
500 |
250 |
0.67 |
500 |
333 |
|
4 |
1000 |
1000 |
500 |
0.67 |
1000 |
666 |
|
5 |
500 |
500 |
500 |
0.5 |
500 |
250 |
|
6 |
1000 |
1000 |
1000 |
0.5 |
1000 |
500 |
|
7 |
500 |
500 |
1000 |
0.33 |
500 |
167 |
|
8 |
1000 |
1000 |
2000 |
0.33 |
1000 |
333 |
|
9 |
500 |
500 |
125 |
0.8 |
625 |
500 |
Additional Resources:
- MIRECS Import Process – This document provides Account Holder with instructions on the MIRECS Import Process.
- Import/Export IRECs – This document outlines the methodology whereby MIRECS will issue Incentive RECs based on imports and how MIRECS will export RECs associated with Incentive RECs.
- What are Peak and Off-Peak Hours? - Link to MIRECS knowledge center article with more information about On-Peak Generation and corresponding IREC calculations.
- REC Imports & Exports Overview - Import and Export rules for all Renewable Energy Tracking Systems and their approximate coverage.