You Already Have Most of the Documentation

The hardest part of a PennAEPS application is proving the savings figure.

Under 52 Pa. Code § 75.62(e), a facility must demonstrate that it generates electricity from or conserves electricity through a Tier I or Tier II alternative energy source. Under § 75.63, a credit is certified for each MWh of electricity generated or conserved. Both turn on a number that has to be defensible.

If you filed a custom rebate application with PECO, PPL, or FirstEnergy, that number already exists and has already been reviewed by someone other than you.

What a custom rebate file contains

Custom incentive tracks pay against modeled or measured savings rather than per-unit values, which means the application has to establish the savings figure rather than assert it. A custom filing typically includes:

• The savings calculation with its methodology — connected load before and after, operating hours, and the basis for each
• Equipment specifications and quantities — fixture schedules, motor nameplate data, drive specifications
• Pre- and post-installation conditions documented well enough for the utility to verify
• Third-party review — most custom tracks route the calculation through the utility's implementation contractor or an independent evaluator before payment
• Completion or commissioning documentation confirming the measure was installed as designed

That is an evidentiary package assembled to satisfy a utility that was about to pay money against it. It is not marketing material.

What transfers

Most of it, though not all of it in the same form.

• The savings figure transfers directly. A verified reduction in annual kWh is the input to the AEC calculation. Divide by 1,000 and you have annual AECs.
• Equipment specifications transfer. They establish that the measure exists and is what it claims to be.
• The methodology transfers. How the savings were derived matters more than the number itself, because certification requires that the reduction be verifiable rather than merely asserted.
• Third-party review carries weight. A savings figure someone else checked before paying against it is a stronger record than one prepared for the application.
• Pre- and post-installation data transfers. Where interval or billing data was used to establish the baseline, it supports continued verification.

What does not transfer

Three things a rebate file will not contain, because the rebate program never asked.

Environmental attribute ownership. The utility does not care who owns the environmental attributes of the reduction. PennAEPS does. 52 Pa. Code § 75.13(i) provides that a customer-generator eligible for net metering owns the alternative energy credits of the electricity it generates, unless a contract expressly assigns ownership elsewhere. Where a project was financed through a PPA, energy services agreement, ESCO contract, or performance contract, the attributes may already be assigned. The default favors the host — but the contract governs, and it needs to be read before an application is prepared.

• Ongoing verifiability. A rebate is paid once against a completed installation. AECs are issued over the measure's remaining useful life, which means the measure has to remain operational and verifiable. That implies a maintenance and documentation posture the rebate never required.
• Environmental compliance verification. Under § 75.62(f), a facility may not be qualified unless the Department of Environmental Protection has verified compliance with applicable environmental regulations and the standards in section 2 of the act. That is a separate check with no rebate-side equivalent.

Timing

Credits are issued from the PennAEPS certification date forward. Generation or savings occurring before certification do not produce credits.

For a measure that has already been installed and rebated, this is the operative point. The measure remains eligible for certification if it has remaining useful life — but issuance begins at certification, not at installation. A retrofit completed in 2023 and certified today generates AECs from today forward across whatever life the measure has left. The elapsed years do not produce credits and are not recoverable.

Which means the rebate file sitting in a project folder is not getting more valuable while it sits there.

The application

Under § 75.64, the program administrator reviews applications, determines geographic eligibility, and provides written notice of the qualification decision within 30 days of receiving a complete application.

The operative word is complete. An incomplete application does not start that clock — it gets returned. Knowing what complete means is the difference between one round and three, and it is the most common reason a straightforward project takes months instead of weeks.

Applications must be verified by oath or affirmation under § 75.62(a).

Materials typically requested include the savings substantiation, equipment documentation, evidence the measure is operational, documentation of environmental attribute ownership, and environmental compliance verification. Requirements vary by measure type and should be confirmed with the program administrator for a specific project.

Worked example

A distribution warehouse files a custom Act 129 rebate for an LED and VFD retrofit. The savings calculation, reviewed by the utility's evaluator, establishes an annual reduction of 3,200,000 kWh.

That figure is the AEC input.

3,200,000 kWh ÷ 1,000 = 3,200 MWh = 3,200 AECs annually

Each month uncertified forgoes approximately $7,179 at the weighted average — revenue the measure will not produce again.

Verify: 3,200 × 26.92 ÷ 12 = 7,179

See the full warehouse model for the underlying assumptions.

If no rebate was filed

Certification does not depend on a rebate. Without one, the savings substantiation has to be built rather than transferred:

• Engineering calculation from the equipment schedule against applicable baselines
• Pre- and post-installation utility data for the affected areas
• Equipment specifications and installation documentation
• Commissioning records where controls contribute to the savings

More work than reusing a rebate file, same pathway.

Frequently asked questions

• Does claiming a rebate reduce AEC revenue? No. They are separate programs. The rebate offsets capital cost; the AEC is issued against the verified electricity reduction under § 75.63. Neither reduces the other.
• Can a rebate file be submitted as the PennAEPS application? No — the applications are different documents with different requirements. But the savings substantiation inside a rebate file is the evidentiary core of an AEC application, which is why a rebated project is materially easier to certify.
• What if the rebate was filed years ago? The file remains useful. Certification is available for measures with remaining useful life. Issuance begins at certification, so the elapsed period does not generate credits, but the documentation still supports the application.
• What if the savings figure was estimated rather than measured? Custom tracks accept modeled savings where the methodology is sound, and so does certification in principle — but the methodology has to be defensible. A calculation that satisfied a utility evaluator is a reasonable starting point.
• Who owns the credits if an ESCO installed the measure? § 75.13(i) provides a default in favor of the customer-generator absent express contractual assignment. Read the agreement — ESCO and performance contracts frequently address environmental attributes, and older ones are often silent, in which case the default applies.

Send us the rebate file

If a custom rebate was filed, most of the substantiation already exists. Send the documentation and we will tell you what it supports and what still has to be assembled.