Response to Comments: ABP Batching Process

July 1, 2020

The Agency would like to thank all stakeholders that provided comments on the recent request for comments about the Adjustable Block Program’s application batching process. Four stakeholders provided comments and the comments did not offer a consensus opinion. Below is the IPA’s proposed approach after reviewing this feedback.

PRIOR BATCHING PROCESS

Under the original Long-Term Renewable Resources Procurement Plan (approved by the Illinois Commerce Commission in 2018 in Docket No. 17-0838), all batches that an Approved Vendor submits to the Program Administrator were required to be at least 100kW (with a 50 kW first batch exception for women- and minority-owned firms, and upon application for small businesses) and no greater than 2 MW in size. At least 75% of the capacity of each batch must be Part I verified for the batch to be eligible to be submitted to the ICC for the Commission’s review and approval.

The Program Administrator submits batches to the ICC at least eight business days prior to a scheduled ICC meeting (ICC meeting schedule is here). The ICC votes to approve batches at that meeting, with each approved batch constituting a new REC delivery contract or a new Product Order to an existing REC contract once executed by each party.

NEW BATCHING PROCESS

Many aspects of the new batching process remain the same as the prior batching process:

Batches of photovoltaic project applications are still submitted by Approved Vendors to the Program Administrator for its review and verification;
Application fees are still due from those Approved Vendors upon submittal of a batch of project applications;
After Program Administrator review and verification of projects, batches are still sent by the Program Administrator to the ICC for its approval on the same 8-business day timetable;
Each ICC-approved batch constitutes a Product Order attached to the REC delivery contract.

However, under Section 6.14.1 of the IPA’s Long-Term Renewable Resources Procurement Plan (approved by the Illinois Commerce Commission in 2020 in Docket No. 19-0838), project applications may now be processed on a rolling basis under circumstances as described below.[1]

If an Approved Vendor does not wish to actively manage the batching of its applications, then batches of Part I verified applications that are at least 100 kW in batch size will be automatically submitted by the Program Administrator to the ICC for approval.
On a rolling basis, the Program Administrator may also submit additional verified project applications from that Approved Vendor to the ICC for approval, whether as an add-on to an existing batch or as an independent batch (with all verified applications being batched together into standalone batches of no more than 2MW of capacity). Those applications processed on a rolling basis may constitute a batch of less than 100 kW in size.
If an Approved Vendor does wish to actively manage the batching of its applications, then it may elect to “rebatch” its verified project applications—including keeping individual verified applications from being submitted by the Program Administrator to the ICC on a rolling basis after verification.
Batches actively managed and shaped at the Approved Vendor’s direction must be at least 100 kW in size to be submitted to the ICC for approval.
For this election, four business days prior to the Program Administrator’s date of submission to the ICC (with that four-business-days-prior referred to herein as the “Eligibility Deadline”), the Program Administrator will provide Approved Vendors with a list of all applications that have been Part I verified prior to the Eligibility Deadline.
Approved Vendors may take one or both of the following elections on a new page in the Approved Vendor portal. Any of these elections that the Approved Vendor chooses to make must be completed no later than 12:00 PM Central Prevailing Time two business days prior to the Program Administrator’s submission date (the “Election Deadline”).:
Completely “rebatch” these Part I verified applications into batches of at least 100kW and no more than 2MW, with the content of that batch or those batches determined at the Approved Vendor’s discretion.
Hold back any individual verified applications from submission to the ICC.
1. Approved Vendors may make the election to hold back a Part I verified application from submission to the ICC no more than twice for any given project application.
2. After the second election, that application may no longer be held back and will be placed into a batch and submitted to the ICC for approval on a rolling basis.
After the Election Deadline has passed, should an Approved Vendor take one or more of the above elections and still have batches containing less than 100 kW of Part I verified projects the Program Administrator will use its discretion to make batching decisions for those projects on behalf of the Approved Vendor prior to the Program Administrator submitting batches to the ICC.

Example:

The ICC is scheduled to meet on Wednesday, July 29, 2020. The Program Administrator must submit batches to the ICC for consideration no later than Friday, July 17, 2020. Approved Vendors will be notified of their eligible Part I verified applications on Monday, July 13, 2020. Approved Vendors may completely rebatch these applications into batches of at least 100kW and/or elect to hold back any of these applications no later than Wednesday, July 15, 2020 at 12:00 PM Central Prevailing Time. Any Part I verified applications that are not a) in a batch of at least 100kW or b) held back from submission to the ICC may either be placed into a new or existing batch or held back from submission to the ICC at the discretion of the Program Administrator.

IMPLEMENTATION TIMELINE

This new batching functionality is tentatively expected to be implemented in mid-August. The Program Administrator will make a subsequent announcement once this functionality is live. No action presently is required by any Approved Vendor regarding this proposed batching process. The current interim batching process will remain in effect until such time as the Program Administrator has announced that the new batching process is implemented.

[1] Note that for a new Approved Vendor who has not yet had a batch approved by the ICC, batches submitted to the Program Administrator must be at least 100 kW in size (with at least 75% of the capacity verified for the batch to be submitted to the ICC for approval) until the ICC has approved one of the Approved Vendor’s batches. Once a batch has been approved by the ICC a new Approved Vendor may follow the process of project applications submitted on a rolling basis as described herein.