We are enabling a corporate PPA between a consumer and a generator. The consumer does not have an individual consumption unit >600GWh but the applicable generators capacity does exceed 10MW. We are not contracting direct with the generator but are registering the export meters to our supply. We will be the registered supplier of the consumer. In terms of cashflow we will be paying the consumer who will in turn pay the generator for the generation. What, in your opinion, would be the best way to report this?
We think it could be either of the following:
- We report transaction(s) with the consumer with the generator as beneficiary
- Consumer reports transaction with Generator only
If option 1 is applicable, and we report both sides of the transaction(s) through our designated RRM, would this mean that all 3 entities have met their reporting requirements or would the generator and consumer still need to submit their own reports?
If it turns out option 2 is the recommended approach, is it possible for us, as a 3rd party, to submit reports on behalf of both the generator and the consumer?
Based on your description we understand that there are two contracts concluded in your example:
- a power purchase agreement concluded between the Consumer and MP A to purchase renewable energy from the generator
- a supply contract concluded between the Consumer and the Generator
MP A and the generator have no contractual relationship.
According to Article 3(1)(a)(vii) of Commission Implementing Regulation (EU) 1348/2014, contracts for the supply of electricity or natural gas to a single consumption unit with a technical capability to consume 600 GWh/year or more are reportable to the Agency. Based on your description we understand the technical capability of the Consumer to consume (being involved in the above-mentioned two contracts) is less than 600 GWh/year, which means that the contracts are not reportable under REMIT.
Please be aware that this conclusion applies only if the Consumer uses the purchased energy solely for own consumption and not for resale. For further information related to the application of Article 3(1)(a)(vii), please refer to Questions III.3.18, III.3.20, III.3.22, III.3.33, III.3.42, and II.4.44 in the Q&A document available in the REMIT Documents section of the ACER website.