Frequently Asked Questions

General Questions

After my distributed generation project has an approved contract under the Adjustable Block Program, can I move the panels to a different building?

No.  The project approval is location-specific.

Are non-ministerial permits required to apply for Block 1?

Systems over 25 kW must obtain all non-ministerial permits prior to applying for Block 1. On the project application Approved Vendors must attest that they have obtained all non-ministerial permits that, according to the commercially reasonable investigation of the Approved Vendor, are necessary to the project at the time of application to the Adjustable Block program. The Approved Vendor must list all such permits, along with the name, phone, and email of a contact person at the issuing authority. The Program Administrator will verify a random selection of permits and reserves the right to verify any permits that it deems require further investigation.

While there is no master list of ministerial and non-ministerial permits, for the avoidance of doubt, the NPDES permit is considered ministerial and not required for submission to the Adjustable Block Program.

 

Are system nameplate sizes AC or DC?

The system sizes listed in the Plan are all AC system sizes based on the size of the inverter.

Can a project be upgraded from a fixed mount panel to a tracker mounted panel after ICC contract approval?

Approved Vendors will not be permitted to make a tracker change between ICC contract approval and the final build. A change such as this would be significant and have a material effect on the project.

Can an ABP applicant withdraw their application once they find out which Block pricing their project will receive?

In the event of a Block 1 lottery for a Group/category, given the drop-off in REC prices between Block 1 and Block 3, some Approved Vendors may not wish to proceed with a project if that project would receive Block 3 pricing. As the Adjustable Block Program is predicated on price transparency and Approved Vendors may have submitted projects into Block 1 on the expectation of Block 1 pricing (possibly even without any expectation of a lottery), the Agency believes Approved Vendors should be allowed to decline a Block 3 award within a short timeframe after selection without additional process or penalty. The Agency thus will allow any project notified that it has received a REC contract with Block 3 pricing as the result of a previous Block’s lottery to have 5 business days to decline its selection prior to the underlying contract being forwarded for approval to the Illinois Commerce Commission. The Approved Vendor will be able to exercise this option without any further penalty, process, or the posting of collateral. If a project selected to be in Block 3 declines its selection by this option, then the next ordinally ranked project(s) on the waitlist will be selected for REC contract(s) at Block 3 pricing until Block 3 is filled, along with the same terms (5 business days to accept or decline). Projects declining a Block 3 contract award will be removed from the lottery order and will be ineligible to receive a contract with Block 4 pricing through the allocation of discretionary capacity. A project may exercise this option to decline a REC contract with Block 3 pricing by communicating as such in writing to the Program Administrator. The application fee is non-refundable.

Can I co-locate multiple distributed generation projects on one parcel of land or adjacent parcels if the aggregate size is over 2,000 kW?

Each unique utility customer may have one distributed generation project of up to 2,000 kW in the Adjustable Block Program.  Two or more utility customers that are affiliated and physically adjacent could each have a distributed generation project of up to 2,000 kW.

Do I need a revenue grade meter or can I just use my inverter reading?

Systems up to 10kW in size are able to use either a meter that is accurate to +/-5% or an inverter specified by the manufacturer to be accurate to +/‐5% that is UL-certified and includes a digital or web-based output display.

Systems over 10 kW and less than 25 kW in size registered with GATS must utilize a meter that meets ANSI C.12 standards. Meters that are refurbished (and certified by the meter supplier) are allowed.

Systems over 25 kW registered in GATS must utilize a new meter that meets ANSI C.12 standards.

All systems registered in M-RETS must utilize an ANSI C.12 certified revenue quality meter.

Note: System sizes are AC nameplate capacity. Therefore a system with a 10kW inverter, for example, is considered a 10kW system regardless of DC nameplate capacity of the system.

 

How can a project demonstrate site control?

Site control must be evidenced through a binding contract for system purchase, lease, PPA, option, or other form. Non-binding documents such as a Letter of Intent do not meet this requirement. It’s acceptable for the binding contract to be contingent on the underlying project securing a REC contract in the Adjustable Block Program, however securing such a REC contract must satisfy that contingency, rendering the contract otherwise binding. In cases where the system owner and host are the same entity, site control can be demonstrated by a statement from the system owner and host that this is the case.

How is the REC obligation calculated for a specific project?

This topic is fully addressed in section 6.14.5 of the Approved Plan. When a project is approved for the Adjustable Block Program, a 15-year REC obligation will be calculated for that project. Approved Vendors will have the option to use either a standard capacity factor or an alternative capacity factor (based on an estimated production analysis from PV Watts or an equivalent tool) to determine the REC obligation for a project. Information on approved capacity factor calculations for use under the program can be found in the Program Guidebook, Section 4: System Eligibility, REC Quantity Calculation

How long do I have to energize my system after acceptance to the Adjustable Block Program?

Distributed generation projects will be given one year to be developed and energized. Community solar projects will be given 18 months to be developed, energized, and demonstrate that they have sufficient subscribers. Extensions may be granted under certain circumstances, as described in more detail in Section 6.15.2 of the Approved Plan.

I live in a rural electric cooperative, municipal electric utility, or the Mt. Carmel Public Utility Company territory. Will I be eligible to participate in the Adjustable Block Program?

The Illinois Power Agency’s Long-Term Renewable Resources Procurement Plan proposed allowing participation in the Adjustable Block Program (for REC incentive payments) by community solar and photovoltaic distributed generation projects located in the service territories of rural electric cooperatives, municipal electric utilities, and Mt. Carmel Public Utility Company. In December, that proposal (along with the Long-Term Plan itself) was presented to the Illinois Commerce Commission for approval, and the eligibility of these projects was affirmed by the Illinois Commerce Commission in its Administrative Order issued on April 3, 2018 in ICC Docket No. 17-0838.

In mid-June, Commonwealth Edison Company filed a petition seeking review of that determination (i.e., an appeal) with the state’s Second District Appellate Court, case number 2-18-0540. As the state appellate court has not granted (or been presented with a request for) a stay or other injunctive relief, the Commission’s decision allowing such projects to participate governs program implementation. As a consequence, barring unanticipated future judicial or legislative action, projects in the service territories of rural electric cooperatives, municipal electric utilities, and Mt. Carmel Public Utility Company, will be allowed to receive REC delivery contracts under the Adjustable Block Program upon the program’s opening for accepting project applications.

While this ongoing uncertainty is unfortunate, we will provide additional details as they become available. Neither the IPA nor its Program Administrator can speculate on the likelihood of the Commission’s decision being overturned on appeal, the timeline for any such determination, or whether an appellate court’s determination would impact the contract or participation status of systems already energized or those with Adjustable Block Program contracts already in place. We will provide additional details on this issue as they become available in the updates section at www.IllinoisABP.com, which you can subscribe to by entering your email address in the “Email Updates” section at the bottom of the home page.

If a lottery were to take place, what process would it follow?

This flowchart explains the process in the case of a lottery for any given Block / category.

If I am awarded a Block 1 REC contract through the ABP lottery, am I obligated to sign that contract?

As the Program Guidebook states at page 35, “[T]he Program Administrator [will] submit contract information to the Commission for approval, [] includ[ing] the Program Administrator’s recommendation for approval of the batch[.]  Once a batch is approved by the Commission, the applicable utility will execute the [REC] contract. The Approved Vendor will then be required to sign the contract within seven business days of receiving it.”  This requirement covers a batch that is approved for a REC contract in a Block through the ordinary non-lottery procedures (see paragraphs C.2 through C.4 on pages 9-10 of the Program Guidebook), as well as a batch that is approved for a REC contract at Block 1 pricing as a result of a Block 1 lottery. Approved Vendors that do not accept the contract will face disciplinary measures that will impact their status as an Approved Vendor in the Program moving forward. It is expected that if a project batch is submitted to the ABP while Block 1 is open, the Approved Vendor is prepared to enter into a contract for Block 1 prices with the applicable utility, although there is an option for a project to withdraw its application within a reasonable time before a lottery occurs for its Group/category.  Through requirements in the Long-Term Renewable Resources Procurement Plan and the Lottery Procedure, the Agency has generally sought to ensure that projects applying to the ABP are ready, willing, and able to advance to development and energization.

There are two exceptions to the general requirement that a project selected for a REC contract must have its Approved Vendor accept the selection. These exceptions, described in paragraphs B.6 and B.7 on pages 8-9 of the Program Guidebook, cover a project selected for Block 3 as the result of a Block 1 lottery, and a project selected for Block 4 from the lottery waitlist.

Is a signed interconnection agreement required to apply for Block 1?

A signed interconnection agreement is required to apply for Block 1 for all systems over 25 kW.

What are the REC prices being offered through the Adjustable Block Program?

The final REC prices can be found in section 6.4 of the Approved Plan.

What is required for a project to apply for Block 1?

Please see the Program Guidebook for the specific application requirements for the Part I and Part II application.

What is required in a shading study?
A shading study shall be completed for all projects. Suitable shading studies can include but are not limited to, using tools such as the Solar Pathfinder, Steprobotics, Helioscope, and HORIcatcher as well as or in conjunction with software designed to perform shading analysis. The shading study should include a list of obstructions with measurements to illustrate that the project meets the minimal shading criteria of no obstruction is closer than a distance (“D”) of twice the height (“H”) it extends above the PV array.
What is the application fee for the Adjustable Block Program?

The application fee for the Adjustable Block Program is $10/kW, not to exceed $5,000, per project. This application fee will be paid to the Program Administrator at the time the batch is submitted. The application fee for each project will be part of the batch submission process and the fee per project will be automatically calculated by the application portal.  Fees may be paid by wire or ACH direct deposit initiated by the applicant using a unique tracking code generated by the application portal in the wire or direct deposit notes section to allow matching of deposits to batch submissions by the Administrator. If the Approved Vendor opts for this payment method, the batch will not be deemed submitted until the application fee is received by the Program Administrator. Approved Vendors will also be offered the ability to request that the Program Administrator withdraw funds from their account via ACH or pay by credit card. The batch will be deemed submitted at the time of submission if either of these methods are used. Credit card payments will be subject to an additional fee of 2.9% of the total payment to account for credit card processing fees and will be limited to no more than $10,000 per month per Approved Vendor.

When can I apply for the program?

The program is now open for applications from Approved Vendors.

Will my information be kept confidential?

Except where otherwise provided (such as with certain project-specific information being made publicly available through publishing lottery results), Approved Vendor submittals including quarterly reports, annual reports, Approved Vendor applications, and project applications will not be publicly posted or made publicly available as a matter of course – provide that nothing included herein shall a) prohibit the IPA from reporting information taken from Approved Vendor submittals to appropriate authorities should the IPA have reasonable suspicion of any fraudulent or otherwise illegal behavior, b) prevent the IPA from making aggregated information taken from across Approved Vendor submittals publicly available, or c) prevent the IPA from sharing information received with the Illinois Commerce Commission or public utilities to support the Program’s operation.

Additionally, the IPA and the Program Administrator will provide confidential treatment to any commercially sensitive information submitted by Approved Vendors in connection with participation in the Adjustable Block Program. Under Section 1-120 of the IPA Act (20 ILCS 3855), the Illinois Power Agency has a statutory obligation to “provide adequate protection for confidential and proprietary information furnished, delivered, or filed” by any third party. As Section 7(1)(g) of the Illinois Freedom of Information Act (“FOIA”) (5 ILCS 140/7) exempts from disclosure “[t]rade secrets and commercial or financial information obtained from a person or business where the trade secrets or commercial or financial information are furnished under a claim that they are proprietary, privileged or confidential, and that disclosure of the trade secrets or commercial or financial information would cause competitive harm to the person or business,” the IPA believes that its responsibility under Section 1-120 necessitates the assertion of this FOIA exemption when applicable in response to a FOIA request, and to otherwise protect the confidentiality of commercially sensitive information in response to any discovery request or other request made in connection with formal investigation or litigation. While the IPA will presume that submittals including quarterly reports, annual reports, Approved Vendor applications, and project applications are commercially sensitive (to the extent not reflecting public information, or otherwise obviously not commercially sensitive) and thus should be actively protected from disclosure, Approved Vendors should designate any particularly sensitive information as “confidential or proprietary” to maximize the likelihood that such information would be protected from disclosure by a reviewing body (such as a reviewing court or the state’s Public Access Counselor) in response to an appeal of the Agency’s determination that such information should not be disclosed in response to a FOIA request.

Will the Adjustable Block Program continue in subsequent years? (i.e. 2020 and 2021)

Section 1-75(c)(1)(C) of the Illinois Power Agency Act calls for at least 1,000,000 RECs annually from the Adjustable Block Program by the end of the 2020-2021 delivery year, then a cumulative 1,500,000 RECs annually from ABP by the end of 2025-2026, then a cumulative 2,000,000 RECs annually by end of 2030-2031. The existing ICC-approved Long-Term Renewable Resources Procurement Plan provides for the first 1,000,000 annual RECs through the ABP, which the Agency intends to select contracts for during calendar year 2019, subject to developer interest fully filling the blocks and subject to RPS budget constraints.  The Agency intends to eventually in future years, again subject to RPS budget constraints, select contracts for at least the first incremental 500,000 annual ABP RECs and then the second incremental 500,000 annual ABP RECs. The law provides for an update to the Long-Term Plan to be proposed by the Agency, first in draft form in August 2019 and then through a 90-day litigation process at the ICC beginning in September 2019.  These changes would take effect beginning in January 2020.

Approved Vendors

Can I self-install my system?

A system applying for the Adjustable Block Program can only be self-installed if the individual installing the system is a Qualified Person which is defined under 83 Ill. Adm. Code § 468.20 as:

“Qualified person” means a person who performs installations on behalf of the certificate holder and who has either satisfactorily completed at least five installations of a specific distributed generation technology or has completed at least one of the following programs requiring lab or field work and received a certification of satisfactory completion: an apprenticeship as a journeyman electrician from a DOL registered electrical apprenticeship and training program; a North American Board of Certified Energy Practitioners (NABCEP) distributed generation technology certification program; an Underwriters Laboratories (UL) distributed generation technology certification program; an Electronics Technicians Association (ETA) distributed generation technology certification program; or an Associate in Applied Science degree from an Illinois Community College Board approved community college program in solar generation technology.

Can I switch Approved Vendors after my distributed generation project on my home or building is accepted to the Adjustable Block Program?

Another Approved Vendor could obtain the rights to your project’s Adjustable Block Program REC contract, but only with the consent of your original Approved Vendor.  See Section 6.7 of the Approved Plan.

Do Approved Vendors need an account in PJM-GATS and/or M-RETS?

Proof of an account in PJM-GATS or M-RETS is required to become an Approved Vendor. This requirement is outlined in Section 6.9 of the Approved Plan.

In PJM-GATS an Approved Vendor can have a generator account (if they have a generator to register) or an aggregator/broker account (does not require a generator). Click here to view the various account types offered by PJM-GATS and the fees associated with those account types.
In M-RETS an Approved Vendor can have a General Subscription, a Project Subscription, a Small Generator Project Subscription, or a Micro Gen Project Subscription (only eligible for one 100 kW batch of generators). Click here to view the various account types offered by M-RETS and the fees associated with those account types.
Do Approved Vendors need to be Distributed Generation Installer certified?

No. The Distributed Generation Installer certification is required by all firms performing actual distributed generation installations, and as such an Approved Vendor may also be a Distributed Generation Installer. However, any entity that meets the Approved Vendor requirements can become an Approved Vendor and doesn’t necessarily need to be involved in the installation process at all, in which case they would not need to be certified as a Distributed Generation Installer.

Do solar installers need to be certified in Illinois?

Yes, there are two requirements for distributed generation installation in Illinois. The first is a company level requirement that Distributed Generation Installers be certified by the Illinois Corporation Commission (ICC). Details of this requirement can be found at the ICC’s Distributed Generation Installer page. A list of Certified Distributed Generation Installers can be found here. Any questions about this requirement should be directed to the ICC which oversees this program.

Additionally, installation of a photovoltaic system, if it will seek a REC contract under the Adjustable Block Program, must be done by a Qualified Person as defined under 83 Ill. Adm. Code § 468.20, which covers the qualifications required of the individuals who are actually installing the system.

How will systems be paid for RECs through the Adjustable Block Program?

For systems up to 10 kW, an upfront payment for the full value of the REC contract will be made to the Approved Vendor at the time the project is fully energized. For distributed generation systems greater than 10 kW and up to 2,000 kW and community renewable solar projects, 20% of the renewable energy credit purchase price will be paid to the Approved Vendor when the project is energized. The remaining portion shall be paid ratably over the subsequent 4-year period. Details on the payment schedule can be found in the  REC contract between the Utility and the Approved Vendor.

What is required to become an Approved Vendor?

The Program Administrator has published a  set of Approved Vendor requirements and marketing material standard disclosure requirements.

Community Solar

How do I find a community solar project to participate in?

A list of approved community solar projects, with contact information, will be found here once projects are approved for participation in the Adjustable Block Program.  Please keep in mind that projects that are in development and have not yet applied to and been approved by the Adjustable Block Program will not appear here. Also keep in mind that some of the projects here may already be fully subscribed. This list will be populated once the program launches.

What is required to sell subscriptions in a community solar project?

The Program Administrator has published a set of community solar marketing material standard disclosures and requirements which can be found here. 

Existing Solar Generator (systems built & energized after 2017-06-01)

Can I enter my home/small business system into the program myself?

All applications will have to be entered by an Approved Vendor. Larger (non-residential) systems of at least 100 kW can apply as a Single Project Approved Vendor.

For small systems that have already been built (and energized after June 1, 2017), if your installer does not become an Approved Vendor, or work with an Approved Vendor, you will need to choose an Approved Vendor from the Approved Vendor list to apply on your behalf once the program opens for project applications.  Each Approved Vendor may offer you different terms and you should choose carefully.

Systems will have to comply with all Program terms and conditions, which may require retroactive adjustments to the system or agreements with the installer.  Systems in the Adjustable Block Program must have been installed by an individual who is a “Qualified Person” as defined in Section 16-128A of the Illinois Public Utilities Act and Title 83, Part 468 of the Illinois Administrative Code.