NEPOOL GIS Update to Rule 4.1(e) – Retail Sub-Account Management

NEPOOL GIS Account Holders,

Earlier today, an emergency NEPOOL GIS Operating Rule change was approved by the NEPOOL Markets Committee which removed the cap placed on retail sub-accounts limiting the number of generation certificates by the number of load obligation certificates. This means if an entity has 1,000 RPS certificates they want to retire in a retail sub-account towards a state RPS requirement, but only has 750 load obligation certificates in their account that quarter, they are now permitted to retire all 1,000 RPS certificates in their sub-account, regardless of their load obligation certificate holdings.

Given the short window between the rule change and the close of the Q4 2016 trading window, the NEPOOL GIS code cannot be updated in time to accommodate this change, HOWEVER, we will be able to process account updates after the close of the Q4 trading period to reconcile any 2016 certificates in to the appropriate retail sub-account as necessary.

If you are in a situation where you are not able to transfer all of your 2016 RPS certificates to your sub-account due to the current load obligation restraints, please follow these steps:

  1. Transfer all certificates that cannot fit in to a retail sub-account to your Reserve account. Fill in the Reserve fields in the following manner:
    • Transferee: 4.1e
    • Voluntary: No
    • Retirement State: Select the compliance state
  2. Email requesting we update your Reserve transactions to a retail sub-account retirement, attaching a spreadsheet detailing the certificates in the request
  3. The NEPOOL GIS administrator will confirm receipt of your request and confirm again after the account update has been completed, both via email

Please note, this request to update Reserve transactions to retail sub-account retirements is a one-time exception. Under normal circumstances the operating rules do not allow for processed Reserve transactions to be converted to retail sub-account retirements.

Deadline: All account updates pertaining to the recent 4.1(e) rule change must be submitted to the NEPOOL GIS administrator before the state RPS compliance deadline pertaining to the certificates involved in the request. For example, 2016 vintage Maine RPS certificates needing a sub-account update will need to be requested before July 1, 2017, which is the Maine annual compliance deadline.


Please contact us with any questions.

NEPOOL GIS Registry Administrator, APX Environmental Markets
2001 Gateway Place, Suite 315W, San Jose, CA 95110