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Notice Of Proceeding And Request For Comments In Annual Review Of Electric Suppliers’ And Electric Distribution Companies’ Compliance With Renewable Energy Portfolio Standards In The Year 2024
PURA established this docket to review and determine the electric suppliers’ and electric distribution companies’ (EDCs) compliance with the Connecticut renewable portfolio standards (RPS) in the year 2024. General Statutes §§ 16-243q, 16-244c, 16-245, and 16-245a. The Authority requires an alternative compliance payment (ACP) if an electric supplier or EDC fails to comply with the RPS. General Statutes §§ 16-244c(h)(1) and 16-245(k).
From Notice of Request for Comments:
[ *** ] Each electric supplier is required to maintain an RPS security (RPS Security) equal to the full ACP payment that the electric supplier would be required to pay to the Authority pursuant to General Statutes § 16-245(k). Conn. Agencies Regs. § 16-245a-1(b)(1). In addition to the RPS Security, each electric supplier is required to maintain a security (License Security) in an amount that will “ensure its financial responsibility and its supply of electricity to end use customers in accordance with contracts, agreements, or arrangements”. Conn. Agencies Regs. § 16-245-4(a)(1). The amount of the RPS Security and the License Security an electric supplier is required to maintain is based on the electric supplier’s forecast year load, which is “the amount of the full load served by the electric supplier during the previous calendar year, as adjusted to account for changes in the type and quantity of customers to be served in the forecast year.” Conn. Agencies Regs. §§ 16-245-42(a)(2)(A) and 16-245a-1(b)(1).
In Docket No. 24-06-01, Annual Review of Connecticut’s Electric Suppliers’ and Electric Distribution Companies’ Compliance with Connecticut’s Renewable Energy Portfolio Standards in the Year 2023, the Office of Education, Outreach, and Enforcement (EOE) proposed modifying the amount of security an electric supplier is required to hold based on data submitted in responses to Interrogatories EOE-4 through EOE-15 in that docket, which is data filed by electric suppliers regarding the electric supplier’s estimated load to be served in the next twelve months, i.e., October 2024 through September 2025. See Motion No. 2, Att., p. 16. In its March 19, 2025 Decision (2023 RPS Decision) in Docket No. 24-06-01, the Authority determined that an electric supplier’s estimated load to be served from October 1, 2024, through September 30, 2025, did not necessarily cover the same time period as the forecast year load, which was January 1, 2023, through December 31, 2023, for 2023 RPS compliance. 2023 RPS Decision, p. 11 fn. 19. It also did not necessarily cover the electric supplier’s estimated load for 2024 RPS compliance, i.e., January 1, 2024, through December 31, 2024. Consequently, the Authority did not consider the data a proxy for an electric supplier’s forecast year load and, as such, did not adjust an electric supplier’s forecast year load based on this data. Id. However, to the extent Participants believed a different methodology should be used for determining “forecast year load,” as that term is defined in Conn. Agencies Regs. §§ 16-245a-1(b) and 16-245-4(a)(2), the Authority stated that Participants may raise it in the 2024 RPS compliance docket, i.e., Docket No. 25-06-01, as both Conn. Agencies Regs. §§ 16-245a1(b) and 16-245-4(a)(2) do allow adjustments to account for changes in the type and quantity of customers to be served in the forecast year. Id.
To facilitate the evaluation of this issue, the Authority requests that Participants file written comments on or before Thursday, May 1, 2025, at 4:00 p.m., addressing the proposed methodology that should be used for the following, including a rationale to support the proposed methodology:
- for determining “forecast year load,” as that term is defined in Conn. Agencies Regs. §§ 16-245a-1(b) and 16-245-4(a)(2); and
- to account for changes in the type and quantity of customers to be served in the forecast year. [ *** ]
Notice of Proceeding (04/02/2025)
Notice – Request for Written Comments (04/02/2025)
25-06-01 (10/29/2024) (Annual Review Of Connecticut’s Electric Suppliers’ And Electric Distribution Companies’ Compliance With Connecticut’s Renewable Energy Portfolio Standards In The Year 2024)

