How is additionality determined?

No additionality or other financial tests are required for a storage asset to be eligible for PECs. Additionality is not required in inventory accounting in the same way as consequential accounting used by carbon offsets. This difference is explained well in the EPA’s guidance comparing RECs and carbon offsets.

The issued storage PECs will have traceability to the additionality indicators of the PECs retired to neutralize charging activity.