Should RECs procured in the REC RFP be associated with a particular generation facility? During what time period should the RECs be generated?
RECs procured must be associated with generation from a renewable resource that occurred between January 1, 2009 and May 31, 2010. RECs generated in that period can be delivered anytime between June 1, 2009 and July 31, 2010, provided that the delivery requirements in the Master Renewable Energy Certificate Purchase and Sale Agreement (“REC SMA”) are met. The REC SMA does not tie REC delivery to generation from a specific facility. A generation owner wishing to deliver RECs from a plant could do so, but would be responsible for delivering the amount of RECs won and not the amount generated. There is no requirement that a REC supplier have a plant on line on June 1, 2009 or deliver RECs from a plant that was on line on June 1, 2009.
