Highland Solar I, LLC Seeks Exempt Wholesale Generator Status with 300 MW Solar Facility in Colorado

Strategic Insights -

Highland Solar I, LLC, a Delaware limited liability company and a wholly owned subsidiary of NextEra Energy Resources, LLC, has submitted a notice of self-certification to the Federal Energy Regulatory Commission (FERC) for its 300 MW solar generating facility and 100 MW energy storage system in Pueblo County, Colorado. The facility will interconnect to the Public Service Company of Colorado (PSCO) transmission system and will primarily engage in wholesale sales of electric energy, capacity, and ancillary services. In addition to the primary activities, Highland Solar I, LLC will also engage in incidental activities such as trading emission allowances, selling "green" power certificates or credits, and other activities permissible under FERC's regulations.

Key Takeaways:

  • Highland Solar I, LLC, a Delaware limited liability company, has submitted a notice of self-certification to the Federal Energy Regulatory Commission (FERC) for its 300 MW solar generating facility and 100 MW energy storage system in Pueblo County, Colorado.
  • The facility will be owned and operated by Highland Solar I, LLC and will interconnect to the Public Service Company of Colorado (PSCO) transmission system.
  • The facility will primarily engage in wholesale sales of electric energy, capacity, and ancillary services.
  • Highland Solar I, LLC will also engage in incidental activities such as trading emission allowances, selling "green" power certificates or credits, and other activities permissible under FERC's regulations.
  • The facility satisfies the definition of Eligible Facilities as defined in Section 32(a)(2) of the Public Utility Holding Company Act of 1935 and as incorporated by reference in 18 C.F.R. § 366.1.
  • Highland Solar I, LLC represents that it will be engaged directly and exclusively in the business of owning and operating the Facility and selling electric energy at wholesale.
  • The Facility includes no transmission or distribution facilities other than those interconnection facilities necessary to permit the Facility to engage in sales at wholesale.
  • Highland Solar I, LLC will not make sales of power at retail.
  • No rate or charge for, or in connection with, the construction of the Facility, or for electric energy produced by the Facility, was in effect under the laws of any State on October 24, 1992.

Statistics:

  • The 300 MW solar generating facility will be located in Pueblo County, Colorado.
  • The facility will have a total of 100 MW energy storage system.
  • Highland Solar I, LLC will own and operate the facility.
  • The facility will primarily engage in wholesale sales of electric energy, capacity, and ancillary services.
  • Highland Solar I, LLC will also engage in incidental activities such as trading emission allowances, selling "green" power certificates or credits, and other activities permissible under FERC's regulations.
  • The facility satisfies the definition of Eligible Facilities as defined in Section 32(a)(2) of the Public Utility Holding Company Act of 1935 and as incorporated by reference in 18 C.F.R. § 366.1.

Sources:

  • UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Highland Solar I, LLC ) Docket No. EG25-____-000 NOTICE OF SELF-CERTIFICATION OF EXEMPT WHOLESALE GENERATOR STATUS OF HIGHLAND SOLAR I, LLC
  • Public Utility Holding Company Act of 2005, enacted pursuant to the Energy Policy Act of 2005, SSSS 1261-77, Pub. L. No. 109-58, 119 Stat. 594 (2005)
  • Section 366.1, 18 C.F.R. § 366.1 (2024)
  • UGI Development Co., 89 FERC P 61,192 (1999)
  • Madison Windpower, LLC, 93 FERC P 61,270 (2000)
  • VESI 12, LLC, 186 FERC P 61,137 at P 16 (2025)