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10 Day Rule for Contracts and Registration in the SRP

On May 1, 2012, the New Jersey Board of Public Utilities (BPU) re-adopted Chapter 8 (renewable energy and energy efficiency) rules with amendments that became effective upon publication on June 4, 2012. The new rule amendments require SREC registration to  occur no later than ten (10) business days after execution of the contract for purchase or installation of the photovoltaic panels to be used for the solar project.  If the applicable deadline is not met, any SRECs based on electricity generated by the solar facility shall not be used for compliance with the New Jersey RPS until 12 months after the solar facility has received authorization to energize by the EDC. See NJ Administrative Code.

The following chart explains this rule further:

  SRP Registration Executed Contract Date
(Day 0)
Compliant Non-Compliant

COMPLIANT
Complete SRP
10 Business Day Rule

A Complete SRP Registration packet is received and includes all documents listed on the SRP Registration Checklist The SRP Registration packet is received (Date stamped) within 10 business days following the date of the executed contract for purchase or installation of the photovoltaic panels
Yes-
COMPLIANT
SRP Acceptance Letter issued
 

NON-COMPLIANT Complete SRP 10 Business Day  Rule

A complete SRP Registration packet is received and includes all documents listed on the SRP Registration Checklist The SRP Registration packet is received (Date stamped) AFTER the 10th business day following the date of the executed contract for purchase or installation of the photovoltaic panels
No
Yes-NON-COMPLIANT SRP Acceptance Letter issued
Incomplete
SRP
An incomplete SRP Registration packet is received and is missing items off of the SRP Registration Checklist and/or missing dates on contract  
No
SRP Registration is returned to the registrant with a letter identifying the missing items. A new SRP Registration is required to be submitted and the new registration date is based on the date the new SRP Registration is submitted to the Program Manager (Date stamped)

NOTE:  Signed & dated executed contract represents day “zero” of the 10 business day requirement.

To remedy the project's lack of compliance with the Chapter 8 rules governing SRP submittal requirements following contract execution, registrants may revise the SRP Registration packet and resubmit it, within one year from the date of the conditional acceptance letter. The revised SRP Registration packet must include all items on the SRP Registration checklist and an updated contract for the purchase or installation of photovoltaic panels to be used in the solar facility with an executed contract date no later than ten business days from the date of resubmission. A cover letter cancelling your non-compliant SRP registration must be included with the revised SRP Registration packet.

You cannot begin construction under the conditional registration prior to submitting a revised SRP Registration packet for compliance without incurring the penalty described at N.J.A.C. 14:8-2.4 (e). If you do not resubmit a revised SRP Registration packet within the required one year period from the date of the non-compliant SRP Acceptance letter, any SRECs based on electricity generated by your solar system cannot be used for compliance in the New Jersey Renewable Portfolio Standard for 12 months, from the date of your EDC authorization to energize.

Once your Final As-Built packet has been submitted, you can no longer submit a revised SRP Registration packet for compliance.


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