Generation Attribute Tracking System (GATS) Overview of PJM-EIS

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1 Generation Attribute Tracking System (GATS) Overview of PJM-EIS Presented at the GATS Subscriber Group Meeting April 15, 2005

2 Overview PJM Environmental Information Services, Inc. (PJM EIS) owns and administers the Generation Attribute Tracking System (GATS). PJM EIS is a wholly-owned subsidiary of PJM Technologies, Inc. PJM EIS was formed to provide environmental and emissions attributes reporting and tracking services to its subscribers in support of portfolio standard and other information disclosure requirements. Users of the GATS will enter into a user agreement with PJM EIS for access to use the system. The user agreement will define the: 1. user fee structure, 2. terms of use, and 3. business rules. 2

3 Overview PJM-EIS expects to have the GATS operational in Q PJM formed PJM-EIS as an equitable way to implement the GATS. - PJM EIS capitalized independently of PJM, L.L.C. - GATS cost borne solely by GATS users - PJM members have no cost responsibility or liability. - FERC has advised that the GATS is nonjurisdictional. 3

4 GATS Subscriber Timeline Milestone / Check Points Task Strategic Alignment Time Line 1Q 05 2Q 05 3Q 05 4Q 05 GATS Participant Development 10/10 Post subscriber agreement to PJM-EIS website 05/16 Conduct GATS Subscriber Group meetings 08/02 Subscriber Group Meeting #1 04/15 Subscriber Group Meeting #2 06/02 Subscriber Group Meeting #3 (NJ only) TBD Subscriber Group Meeting #4 (MD only) TBD Finalize operating rules upon feedback 08/02 Conduct user training User Training Class #1 User Training Class #2 User Training Class #3 08/17 08/01 08/09 08/17 User Registration begins 08/02 Conduct trial operations 08/29 Certificate Trading begins 09/09 1 st monthly GATS bill issued 10/10 4

5 Overview of GATS Subscription Agreement

6 Agreement Basics Use of the GATS All GATS users including state agencies must enter into a subscription agreement with PJM EIS. Users will have non-exclusive use of the GATS application. Use granted only to the user, its parent and any of its wholly-owned subsidiaries that open user accounts, but does not extend to affiliates or other related parties. Users will be charged a subscription fee and volumetric fees for use of the system. By signing the agreement, users attest that the information they provide into the GATS database will be true and correct and that they will comply with all of the requirements of the GATS operating rules. 6

7 Agreement Basics Term and Termination The agreement term is perpetual unless terminated by one of the parties. Either party can terminate the agreement for any reason upon giving 60 days written notice to the other party. EIS can terminate the agreement for cause immediately upon giving notice if a user breaches any term of the agreement including, but not limited to, failing to pay any fees when due and willful misrepresentation of data input into the GATS database. User must cease using the system immediately upon termination of the agreement. User fees already paid to EIS will not be prorated upon termination of agreement. 7

8 Agreement Basics Dispute Resolution Process EIS will implement a dispute resolution process pursuant to which a GATS user can request that the GATS administrator reverse a transaction for GATS users who mistakenly perform a transaction that the GATS user cannot reverse (such as a transfer to a Reserve Subaccount) Certificates A generation unit located outside of the PJM system must attest that: It only uses the GATS for creating its certificates. The attributes for which a particular GATS certificate has been created have not previously been transferred to another entity. 8

9 Overview of GATS Fee Structure

10 Agenda Annual Subscription Fees Volumetric Fees Reserve Sub-accounts Monthly Billing Process 10

11 Annual Subscription Fees $2,000/year fee for PJM load serving entities (LSEs) that use the system $1,000/year for non-lses, brokers, traders and renewable generators No annual fee for renewable generators with aggregate generation under 10 MW No annual fee for non-transacting state regulators No annual fee for non-renewable generators Annual fees will be prorated based on the account holder s start date. On-going annual fees will be billed each December for the subsequent year. 11

12 Volumetric Fees LSE s fee of $0.008/MWh determined against net load served in states in which the LSE uses GATS. Fee calculated monthly based on net load in the account holder s retail LSE sub-accounts associated with those states. 12

13 Volumetric Fees Fee of $0.25/MWh for certificates transferred into a reserve sub-account, unless it is used for compliance with a PJM-state renewable portfolio standard (RPS) Fee calculated monthly based on certificates transferred into a reserve sub-account, excluding certificates used for compliance with a PJM-state RPS 13

14 Reserve Sub-Accounts Compliance with a PJM-state RPS Make environmental claims Sold as part of a retail certificate-only product to an enduse customer that does not have a GATS account Exported off-system to a third party in a region that does not have a compatible tracking system Exported to a compatible tracking system 14

15 Billing Process Invoices will be sent out monthly. Invoices will be sent electronically to an address designated by the user. Invoices will be due 30 days from invoice date. Wire payments are preferred. 15

16 Overview of GATS Operating Rules

17 Presentation Overview System Functionality Overview Data Sources GATS Account Structure Certificate Creation Behind the Meter Generation Imports and Exports 17

18 System Functionality Overview GATS - a regional information system that will track the environmental attributes of generation and will support reporting, compliance and verification requirements related to environmental compliance and related markets. The system will: assist LSEs in their compliance with applicable emissions and fuel disclosure requirements, assist LSEs in their compliance with state-level RPS regulation or renewable policy, and enable voluntary bilateral markets for renewables. 18

19 System Functionality Overview The system will have provisions for: - banking certificates to accommodate varying certificate life spans as determined by state policy or regulation - enabling varying state programs and their definitions of preferred attributes: wind, solar, biomass, etc. waste coal pumped storage generation - moving certificates to non-lses for bilateral voluntary markets, i.e. direct sales to retail entities - A bulletin board to facilitate bilateral trades - Behind the meter generation, imports and exports 19

20 Gen 1 System Functionality Overview Each generator can have a GATS account: Gen 2 - As MWh are generated, a certificate is created in each generator s account. - Distributed generation sources may be combined by an aggregator. 20 Gen 3

21 System Functionality Overview Each MWh is given a unique electronic certificate Certificate No Acme Generating Station Pollutant lbs NOx 1.5 SO CO2 1,900 Fuel: Natural Gas Location: Example, NJ N.J. Class I: No N.J. Class II: No 1 MWh This certificate may contain any information relevant to market participants and capable of being tracked by GATS. - Certificates data will be compiled using PJM generation and publicly available data from EPA and EIA. - Where data do not exist or are faulty, generators may choose to update their information based on agreed upon best practices. - Default assumptions will be developed as a last resort for generators with faulty or no data who choose not to update their information. 21

22 Each LSE also can have a GATS account: System Functionality Overview LSE MWh PJM tracks load served by each LSE 22

23 System Functionality Overview Gen 1 Each LSE needs certificates sufficient to cover its load LSEs may obtain these certificates from specific generators or take the residual mix. LSE Gen 2 Gen 3 - Certificates for a given calendar year can be bought, sold or transferred anytime after the certificates are created until the trading period closes. - Generators must release their certificates and an LSE must accept them for a transaction to be valid. 23

24 System Functionality Overview GATS account holders also can set up clean energy portfolio standard (CEPS) accounts CEPS accounts allow certificates to be retained after the trading period ends. States determine CEPS eligibility (RPS resources, resources identified as environmentally preferred, etc.) Wind Wind Wind Solar Biomass Solar Biomass Biomass Solar States determine lifespan of CEPS eligible certificates. CEPS certificates can be accumulated and/or transferred. CEPS certificates do not appear on an LSEs disclosure label. 24

25 System Functionality Overview Gen 1 Gen 2 Gen 3 Matching untransfered certificates with LSE load (for fuel mix and emissions disclosure purposes) Residual Mix Pool - At the end of the year (plus a true-up period), unsold/unused certificates will be retired. The attributes of those unused certificates will be pooled to create residual mix certificates. - Each LSE with unmatched load (more MWh than certificates) will be allocated an equal number of residual mix certificates which can be used only for fuel mix and emissions disclosure purposes. 25

26 System Functionality Overview End of Trading Period Processing LSE - At the end of the trading period (plus a true-up) the residual mix is assigned to MWh without certificates. - GATS accounts for trading period are now locked - these certificates may not be traded again. - Exception: certificates in CEPS accounts remain active and can continue to be traded these certificates will not appear on any disclosure label. - Reports are generated for the LSEs/regulators. - Market participants who make marketing claims or are required to comply with a particular state RPS or disclosure rule can use these reports to verify their claims to customers and/or to demonstrate compliance to regulators. - The system starts over in the new trading period. 26

27 Data Sources Description Source Comments Generator Output (MWh) Load Served (MWh), by state Fuel Source(s) Market Settlement System, Generation Reporting System, or Generator Entered Market Settlement System Generator Entered BTM resources will enter generation and emissions data periodically Emissions Data (lbs): Carbon dioxide Nitrogen oxides Sulfur dioxides U.S. EPA where available, otherwise generator entered Other emissions that might be tracked in the future: Carbon monoxide Mercury Particulate matter Particulate matter 10 microns or less Volatile organic compounds 27

28 Data Sources Description Source Comments Generator Asset Information: Vintage (date of commercial operation) Repowering date and capacity addition FERC hydroelectric license relicensing date PJM Unit ID EPA Unit ID Asset owner Status (active, retired or expired) Month and year of generation Capacity Location of unit (State, Control Area, NERC Region) RPS Eligibility (by state). For example: New Jersey o Class I renewable energy source (yes/no) o Class II renewable energy source (yes/no) o state certification number o eligibility end date Generator Entered Generator Entered Green-E Eligibility Generator Entered Optional EIS will populate these static data fields using publicly available information where possible. Optional. A state certification number is required for each state for which the eligibility status is set to yes. 28

29 GATS Account Structure The account structure for a GATS account holder contains four types of subaccounts: - active subaccount - CEPS subaccount - retail LSE subaccounts (This type of subaccount is applicable only to LSE users that must have at least one retail LSE subaccount for each state in which they serve load.) - reserve subaccount. GATS certificates are originally deposited in either the active or CEPS subaccount based on the source of generation. Account holders can then transfer GATS certificates to the other subaccounts as described in the operating rules. 29

30 GATS Account Structure When transferring to a reserve subaccount, the account holder must specify for what purpose the certificates are reserved: for compliance with a state renewable portfolio standard to make environmental claims or to take out of circulation for environmental benefits reasons sold as a part of a retail certificate-only product to an end-use customer that does not have a GATS account - For example: sold to residential or commercial customers making voluntary purchases sold to event organizers so that events can offset their electricity or make environmental claims. exported (sold) off-system to a third party in a region that does not have a compatible tracking system exported to a compatible tracking system other 30

31 GATS Account Structure Generator Reporting System (BTM & External Generators) Compatible Tracking System PJM Market Settlement System Pumped Storage CEPS Tracking Active Sub Account Disclosure Subsystem CEPS Sub Account In Retail LSE Sub Accounts On Bulletin Board Account Name #1 State = XX Account Name #3 State = XX Reserve Sub Account Once certificates are placed in the Reserve sub account they cannot be transferred out Account Name #2 State = XX Account Name #4 State = XX 31

32 Certificate Creation GATS Timeline 2/28-2/24 Trading Period Q1 Q2 Q3 Q4 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr 2/28 3/31 4/29 5/31 6/30 7/29 8/31 9/30 10/31 11/30 12/31 1/31 6/1 Q1 Preliminary Report 9/1 Q2 Preliminary Report 12/1 Q3 Preliminary Report 3/1 Q4 Reports Certificates created monthly to increase flexibility and accommodate differing state reporting periods Preliminary reports issued each quarter Annual settlement in late February for the preceding calendar year CEPS-eligible certificates can be transferred to a CEPS subaccount any time prior to the annual settlement date so that they can continue to be traded. 3/15 Annual Reports 32

33 Certificate Creation Certificate Creation Last Business Day PJM Settlements Completed 1 st thru 5 th Business Day Dynamic Data Import and Verification 6 th thru 9 th Business Day Account Holder Review Period 10 th thru next to last Business Day Certificate Creation Timeline - Month following month of generation) Certificates created monthly on last business day of the following month Account holder review period spans from the 10 th business day to the day before certificates are created If a multi-fuel generation unit does not provide a breakdown of generation by fuel type prior to the certificate creation date, all of the certificates created for the unit shall be deemed to have the primary fuel type, and none of the certificates will be considered eligible for any state programs. 33

34 Behind the Meter Generation GATS will be designed to allow for the participation of behind the meter (BTM) generation. A participating BTM generation aggregator or owner will be able to register for and manage a GATS account. BTM participation in GATS will be in accord with individual state jurisdictional policy, notably decisions on BTM generation qualification in policies such as a clean energy portfolio standard or green energy procurement programs. BTM generators must supply evidence of state certification for their participation, which should include provisions for verification and audit of meter data. The GATS will track and identify the state in which the BTM generator s attributes are qualified. Certificates for BTM generation are deposited directly into a CEPS subaccount. They will not appear on a retail LSE disclosure label. 34

35 Behind the Meter Generation BTM generation and emissions data will be collected by the aggregator or owner, in compliance with state policy, and reported to the GATS. BTM generation data will be submitted to the GATS periodically. BTM generation data does not need to be submitted monthly, but it must be submitted no less frequently than annually. For smaller BTM generators the generation data can be accumulated but must be reported in whole MWh increments. EIS will assume no responsibility for verification or accuracy of the supplied data. 35

36 Imports Imports Certificates for energy imported from a specific generating unit will reflect the attributes of the generating unit if 1. the external energy resource was scheduled and delivered into the PJM control area, and 2. the seller certifies that the specified attributes have not been used for any other purpose. Otherwise, energy imports that are not accounted for through the designation of specific certificates will be assigned attributes of the system average for the control area from which they are purchased. Certificates-only imports into the GATS will be permitted subject to qualifications to be determined by the PJM states. GATS will not dictate policy in this area. Qualified certificates will be deposited into an account holder s CEPS subaccount. The certificate must be CEPS-eligible in a state. CEPS eligibility is determined by the states. For example, states might require that imported certificates originate in a region that has 1. a compatible tracking system, and 2. offers reciprocal treatment of GATS certificates. 36

37 Exports All external sales of energy that are not accounted for through the designation of specific certificates will be assigned certificates with the average of the residual mix. Certificates may be exported (i.e. sold offsystem) without associated energy by transferring the certificate to a reserve subaccount. This is the mechanism by which GATS certificates would be exported for conversion to a compatible tracking system. Exports 37

38 If you have any questions For more information on GATS: Ken Schuyler (610) Jaclynn Geist (610)