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Parties Files Comments On Adjustment To RPS 2023 Class III Requirement
Re: Pursuant to statue, the Department of Energy is authorized to adjust Class III RPS requirements as necessary and consistent with the purposes of RSA 362-F. The Department will consider whether an adjustment should be made to the Class III requirement for 2023.
As background, the Department of Energy has determined to evaluate whether a sufficient supply of Class III (Existing Biomass/Methane) renewable energy certificates (RECs) will be available for New Hampshire electricity providers to comply with New Hampshire’s Renewable Portfolio Standard (RPS) requirements under RSA chapter 362-F for the 2023 compliance year. The Department will consider whether an adjustment should be made to the Class III requirement for 2023. If the Department makes no change, the Class III RPS requirement will be 8.0 percent of retail sales for 2023.
Excerpts from RESA Comments:
{***} On January 17, 2024, the Department of Energy (“Department”) issued an Order of Notice of Public Comment Hearing regarding proposed adjustments to the Class III Renewable Portfolio Standard (“RPS”) obligation for the 2023 compliance year.1 The Retail Energy Supply Association (“RESA”)2 hereby submits its comments in response to the Notice. For the reasons set forth more fully below, RESA urges the Department, as it has done in the past,3 to exercise its authority to reduce the Class III compliance obligation.
As the Notice points out, there has been “reduced production from a number of Class III certified biomass facilities during the 2023 calendar year.”4 In addition to this production shortage, there is demand for New Hampshire Class III renewable energy credits (“RECs”) in neighboring states that will make even fewer of those RECs available to satisfy the New Hampshire RPS obligation. New Hampshire Class III RECs qualify to meet the RPS requirements in other New England states with higher Alternate Compliance Payment (“ACP”) rates than the current New Hampshire ACP. As a consequence, the limited number of New Hampshire Class III RECs produced will likely be used by suppliers, as they have in the past,5 to satisfy the RPS obligations in those neighboring states. {***}
Order of Notice for Compliance Year 2023
First Point Power Comments (01/23/2024)
Constellation NewEnergy, Inc. Comments (01/23/2024)
New Hampshire Electric Cooperative, Inc. Comments (02/01/2024)
RESA Comments (02/01/2024)
2023 Compliance Year Class III Obligation Review
