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Frequently Asked QuestionsExpand All [+]
The Michigan Renewable Energy Certification System (MIRECS) issues, tracks and enables trading and retirement of credits through a unique, traceable serial number issued for every megawatt hour (MWh) of qualifying energy generated by facilities registered with MIRECS. The credit types include Michigan Renewable Energy Credits (RECs), Advanced Cleaner Energy Credits (ACECs) and Michigan Incentive Renewable Energy Credits (ICs). Energy Optimization Credits (EOCs) will be added at a later time. The system is set up to also support linkages with other state and regional renewable energy market programs. Yes. The Michigan Renewable Energy Certification System was developed to serve as the tool to implement and verify compliance with the Michigan clean, renewable, and efficient energy act. MIRECS can also be utilized for transactions in the voluntary marketplace. With the Registry, all participants in the Michigan market are able to take advantage of a trusted infrastructure to help manage their role in the market. Benefits include: Michigan Electric Service Provider Account: This type of Account can hold, transfer (outgoing and incoming), and Retire credits. A Michigan Electric Service Provider Account can also register and maintain Projects and have credits issued to it for its projects. A Michigan Electric Service Provider Account is the only type of Account that can retire credits for compliance with the Michigan Renewable Energy Standard. Non-profit Wholesale Power Provider Account: A non-profit entity that supplies wholesale electric power to one or more Michigan Electric Service providers which maintain accounts on MIRECS. This type of Account can hold, transfer (outgoing and incoming), and Retire credits. This Account type can also register and maintain Projects and have credits issued to it for its projects [This account type will be available starting November 15] General Account: This type of Account can hold, transfer (outgoing and incoming), and Retire credits. A General Account can also register and maintain Projects and have credits issued to it for its projects. Project Account: This type of Account can register Projects and have credits issued to it for its projects. A Project Account can hold, transfer (only outgoing transfers), withdraw and Retire credits. A Project Account cannot receive transfers from other parties. Retail Purchaser Account: This type of Account is for retail purchasers of credits. A Retail Purchaser Account can hold, accept incoming transfers, and Retire credits. They can also register and maintain projects that are under 1MW in capacity and have credits issued in their Account. A Retail Purchaser Account cannot make outgoing transfers. Qualified Reporting Entity (QRE)/ Verifier Account: An Account Holder with a QRE Account is assigned to one or more project(s) and is responsible for verifying generation information from that project. MIRECS tracks the specific types of projects for which QRE’s are approved to provide services, ensuring that they are suitably qualified and accredited. The QRE Account cannot hold credits. Program Administrator Account: This type of Account is provided to administrators of compliance and voluntary programs that utilize MIRECS and/or have eligibilities noted for certain Credits. It will allow Program Administrators to review eligibilities and compliance reports. Asset details will only be displayed in a Program Administrator Account if the Account Holder registering that Asset has listed it as eligible according to the specific program/certification. MIRECS stores and publicly displays renewable energy generator and project information. MIRECS also facilitates independent third-party certification and auditing of renewable energy generator projects as well as certificate retirement records. Once a generating asset is registered and appropriate certificate documentation, affidavits and attestations are uploaded, the MIRECS administrator will issue one Renewable Energy Credit or Advanced Cleaner Energy Credit for each megawatt-hour (MWh) of eligible energy reported to MIRECS. Applicable Incentive Renewable Energy Credits will also be issued at this time. The asset owner then uses MIRECS to transfer credits to another account holder or retire the credits. MIRECS ensures the integrity of the credits through a transaction-based data structure designed to prevent double-counting and provide full audit trail capabilities. Additionally, MIRECS provides numerous publicly accessible reports that list Account Holders, the status of generators and projects, and information about both issued and retired certificates.. The Michigan Renewable Energy Certification System is powered by the most widely used, highest volume, and technically advanced environmental market infrastructure that has been developed over nearly a decade. With more than 2 billion certificates under management, APX market infrastructure sets the standard for ensuring integrity in environmental markets. As an independent and trusted provider of infrastructure solutions, APX is fully committed to the highest market transparency and a level playing field for all market participants and stakeholders. We do not make markets or take principal positions in environmental transactions, and are not a bank, brokerage or marketer. Every generator has to provide documentation substantiating the generation of renewable energy. The documentation requirements can include metering records, official filings with the Energy Information Administration as well as independent reporting from qualified third parties. Anyone can have an account in the Michigan Renewable Energy Certification System. Obtaining an account requires completing the account registration process and paying the account registration fees. A renewable energy project can be registered by anyone who has legal title to the project. Typically this would be a generator owner or a project developer. The Registry accepts renewable and alternative energy generation technologies that are eligible under Michigan’s clean, renewable, and efficient energy act. Generation data can be issued for generation up to one year prior to Generator approval in MIRECS. The lone exception to this is for facilities that register before March 31, 2010 as they will be able to load generation data going back to January 1 2009. No Credits will be issued for generation prior to January 1 2009. Functionality related to Energy Optimization Projects and Energy Optimization Credits may be added to MIRECS in the future. Currently, Energy Optimization Credits are not transferable. Therefore, electric service providers who are accumulating energy optimization credits are documenting them internally subject to verification in an annual reconciliation proceeding before the Commission. In 2011, the Commission is required to make a report and recommendation to the Michigan legislature concerning a program for transferability of energy optimization credits. It will most likely be some time after the report in 2011 that functionality related to energy optimization credits may be added to MIRECS. A participant seeking to meet its Michigan PA295 compliance obligations must retire credits in its own account. Participants seeking to retire credits on a voluntary basis may do so through third parties, subject to certain terms and conditions. See generally Section 6 of the Terms of use, which discusses these provisions. Michigan requires that every Michigan Electric Service Provider retire credits only for their own obligation. The Michigan Renewable Energy Certification System is not an exchange. An exchange matches buyers and sellers in a transaction, and the Registry does not do this. Buyers and sellers may identify each other using reports and public documents provided by the Registry, but deal negotiation and financial transactions happen outside the Registry. Once the financial transaction occurs, the seller uses the Registry to transfer certificates into the buyer’s account. So the Registry is the system of record to complete the physical transaction, perform the transfer, and reflect the sale. Currently, the Michigan Renewable Energy Certification System tracks certificates originating MIRECS. However APX is working to enable the ability to transfer credits from one registry to another. Michigan Electric Service Provider Account: This type of Account can hold, transfer (outgoing and incoming), and Retire Credits. A Michigan Electric Service Provider Account can also register and maintain Assets and have Credits issued to it for its Assets. NOTE: A Michigan Electric Service Provider Account is the only type of Account that can Retire Credits for compliance with PA295. Non-profit Wholesale Power Provider Account: A non-profit entity that supplies wholesale electric power to one or more Michigan electric service providers that maintain a Michigan Electric Service Provider Account. This type of Account can hold, transfer (outgoing and incoming), and Retire Credits. This Account type can also register and maintain Assets and have Credits issued to it for its Assets. General Account: This type of Account can hold, transfer (outgoing and incoming), and Retire credits. A General Account can also register and maintain Assets and have Credits issued to it for its Assets. Project Account: This type of Account can register Assets and have Credits issued to it for its Assets. A Project Account can hold, transfer (only outgoing transfers), withdraw and retire Credits. A Project Account cannot receive transfers from other parties. Retail Purchaser Account: This type of Account is for retail purchasers of Credits. A Retail Purchaser Account can hold, accept incoming transfers, and retire Credits. They can also register and maintain Assets that are under 1MW in capacity and have Credits issued in their Account. A Retail Purchaser Account cannot make outgoing transfers. Qualified Reporting Entity (QRE)/ Verifier Account: An Account Holder with a QRE Account is assigned to an Asset and is responsible for verifying generation or storage information from that Asset. MIRECS tracks the specific types of Assets for which QRE’s are approved to provide services, ensuring that they are suitably qualified and accredited. The QRE Account cannot hold Credits. Program Administrator Account: This type of Account is provided to administrators of compliance and voluntary programs that utilize MIRECS and/or have eligibilities noted for certain Credits. It will allow Program Administrators to review eligibilities and compliance reports. Asset details will only be displayed in a Program Administrator Account if the Account Holder registering that Asset has listed it as eligible according to the specific program/certification. More details on the different account types can be found in the Operating Rules and Terms of Use. The Terms of Use is a standard document common to all users of MIRECS. This document cannot be customized for each user as all changes to the Terms of Use will need to be applicable to all current Registry subscribers. MIRECS was established by the Michigan Public Service Commission (Commission or MPSC) under authority conferred by 2008 PA 295. MIRECS is administered by APX, pursuant to a contract with the State of Michigan, Department of Energy, Labor & Economic Growth. The Michigan Public Service Commission is the effective governing body. The Commission has delegated day-to-day administration of the contract to the Electric Reliability Division. All interested parties are welcome to subscribe to MIRECS Updates by visiting the MIRECS website and filling out the subscription form there. Entities are encouraged to communicate about any MIRECS issues by contacting APX. APX discusses all MIRECS substantive and policy issues with the Commission Staff. As indicated in the MIRECS Terms of Use, Section 26, Electric Reliability Division Staff is available to assist parties in the informal dispute resolution process, if necessary. In addition, Account Holders will be invited to participate in a MIRECS Stakeholder Advisory Group, for the purpose of facilitating communications and providing recommendations for system changes and improvements. Dispute resolution procedures are described in the MIRECS Terms of Use, Section 26, Governing Law and Dispute Resolution. The procedure begins with informal dispute resolution efforts with APX. Commission Staff will assist at the request of either party. If the informal effort is unsuccessful, the process calls for formal mediation, then arbitration, if necessary. Projects (generators) that are submitted for approval in MIRECS by March 31, 2010, will have the option preserved to have Credits issued back to January 2009. Delays in processing or the lack of any system capabilities that are the responsibility of APX or the Commission Staff will not result in the loss of opportunity to have RECS issued back as far as January 1, 2009 for those Projects. Account Holders that have made all reasonable efforts to complete Project registrations by the March 31 deadline should not experience problems with respect to the deadline. Staff has directed APX to work with Account Holders to enable the transfer of RECs from other registries as close as possible to the time of the owners’ choosing. Michigan Electric Service Providers who purchase power from Non-Profit Wholesale Providers will retain the option of using Credits back to January 2009 if they register before their 2011 renewable energy plan biennial review process commences. APX is contractually obligated to make the import/export functionality available to MIRECS users. APX, in consultation with the Staff, has been working with other REC tracking registries to define requirements for providing a reliable method for credits to be imported or exported between registries, while maintaining REC validity. Due to the complexity of this process, the import/export capabilities will not be available by the March 31, 2010 registration deadline. This deadline was established to set a baseline for the eligibility of 2009 RECs for 2012 compliance, and will not affect the eligibility of RECs from 2009 that are registered in another REC tracking system. Because these credits are not needed at this time for Michigan compliance, a delay in their transfer from one system to another will not materially affect any Michigan provider's ability to meet the requirements of PA 295. Yes, subject to the qualification that imported RECs must meet the Michigan definition for renewable energy and otherwise comply with the provisions of 2008 PA 295. If RECs originate in M-RETS or GATS, all applicable Michigan incentive credits will be assigned upon importation into MIRECS. The creation of incentive RECs is dependent upon proper documentation and authentication data being supplied by the originating registry. If this data is not transferred with the RECs, it will be the responsibility of the REC owner to provide affidavits and the data necessary to validate the particular Michigan incentive credit(s). No. Users are free to develop their own or utilize third party software that will be used in conjunction with the MIRECS system, MIRECS data, and MIRECS reports. However, such user-developed or third party software used in conjunction with MIRECS shall not, in any way, interfere with, put at risk, corrupt, injure, impair, or degrade the operations of the APX developed MIRECS system. Staff is working with APX to clarify the language. Yes. The Account Holder will have access to the dispute resolution procedures contained in Section 26 of the Terms of Use. In addition, Staff is exploring with APX the possibility of expanding the time window for payment before the immediate access termination may be triggered. The current language in the Terms of Use provides for the retirement or transfer of RECs to another registry participant's account prior to the termination of access. However, Staff plans to explore with APX the option of holding the RECs in escrow during the pendency of a related dispute resolution procedure. This may result in another modification to the Terms of Use. Yes. The MIRECS dispute resolution procedures may be used. This requirement is standard operating procedure for online software applications, and is deemed reasonable upon review. It is unrealistic to expect APX to request feedback and approval from users for every change to its Terms of Use or Operating Procedures, however insignificant. This should not be construed to imply any lack of oversight, though. MPSC Staff reviews and approves all proposed substantive changes to these documents. Further, APX agrees to notify users of changes to the Terms of Use or Operating Procedures through the MIRECS update email distribution list and through the use of messages that will appear when Account Holders log onto the system. APX is bound by its contract with the State of Michigan. This contract places limitations on both the application and contractor (APX) and should ensure reasonable outcomes. Under the State's contract with APX, APX is required to comply with all Operative Documents unless, after consultation with the State of Michigan (Commission Staff), "such compliance would have a material adverse effect on the Registry." APX would be required to report this non-compliance to Account Holders within thirty (30) days. Presumably, if this occurs, it would precipitate a change to one or more of the operative documents. The Michigan Renewable Energy Certification System strikes a balance between respecting the privacy of certain account holders and providing the public with complete Registry transparency. As a result, MIRECS provides a number of publicly accessible reports that provide comprehensive information about the renewable projects without requiring account holders to disclose their presence or their credit inventory. The reports provide comprehensive information about all renewable energy projects. Any account holder in possession of credits, including their own, can retire the credits. MIRECS uses the MISO definition of On Peak Hours. On Peak period is defined as Period of time from 0700 hours EST through 2200 hours EST ( Hour 7 and 22 inclusive) Monday through Friday except New Year's, Memorial Day, Fourth of July, Labor Day, Thanksgiving Day, and Christmas Day or if the holiday occurs on a Sunday, the Monday immediately following the holiday. The definition of Qualifying Michigan Equipment is the construction of equipment directly relating to the renewable energy systems. The ancillary equipment used to operate or access a generating station or substation should not be included in this calculation. APX is the leading infrastructure provider for environmental and energy markets in renewable energy and greenhouse gases including renewable energy certificates (RECs), energy efficiency and conservation certificates, carbon offset certificates such as voluntary emissions reductions (VERs), and greenhouse gas emission allowances. With a singular focus on providing trust, transparency, and integrity for environmental markets, the company is the solution of choice for every major renewable energy market in North America and greenhouse gas markets worldwide. APX provides 24/7 support of environmental markets through secure, fully staffed and geographically redundant data centers. Users of these systems include all key market participants including brokers, corporations, generators, NGOs and government organizations. In 2009, more than 1300 companies across the US and internationally will rely on APX for integrity in environmental markets. APX also provides technology, strategic consulting, and expert operational services to assist wholesale power market participants reduce costs and improve performance in power scheduling, settlement, market operations, system operations support, and demand response programs. |
