May purchases from a power pool qualify as specific purchases for purposes of the retail supplier report?
A. Yes. Pooling and brokerage are acceptable ways of bringing buyers and sellers together in specific purchase transactions. For example, an exchange may operate as a pool containing various kinds of electricity. Energy Commission’s regulations, at 1394 (b)(3), refer to “a pool of renewable power”. However, for purposes of tracing specific purchases, it is not clear that such a pool needs to consist entirely of renewable power, as long as the pool provides an audited filing to the Commission verifing the amounts of energy, by fuel or technology type, delivered to and from the pool. The pool’s filing must identify specific generation sources as described in 1394 (a)(2)(B) of the regulations. Renewable power sold to investor-owned utility companies and their customers under standard offer contracts is not eligible for specific purchase through a pool or in any other way.
