Under the REC Contract, a Project must deliver at least one REC to each Company on or before May 31, 2021 unless such deadline is extended to May 31, 2022 by the Seller opting to meet an increased collateral requirement.
The Date of First Operation is information that is required in the Part 1 Proposal as part of the information about the Project, along with information about site control and milestones achieved. The Date of First Operation provided in the Part 1 Proposal is required to be March 30, 2022 or before. As you point out, this requirement was set recognizing that the Seller may post increased collateral requirement to extend the deadline for first REC delivery to May 31, 2022, and accounting for the required time for RECs to be produced according to PJM EIS GATS and M-RETS procedures.