Month: October 2020

Revised DG Marketing Guidelines Reminder – Grace Period Ends October 31, 2020

The revised Adjustable Block Program Distributed Generation Marketing Guidelines were published on September 16, 2020. These revised guidelines apply to all distributed generation sales and marketing activity from that date forward. Approved Vendors and those operating on their behalf are expected to be familiar with all changes and adhere to all requirements outlined in the revised guidelines.

As a reminder, there is a grace period of 45 calendar days from September 16, 2020 before disciplinary action is taken for violations of new, non-emergency requirements found in the revised guidelines. This grace period will end on Saturday, October 31, 2020. This grace period only applies to items that have changed from the original DG Marketing Guidelines to the revised DG Marketing Guidelines. Any violations of these items by Approved Vendors or their Designees may result in disciplinary action.

Emergency restrictions against door-to-door marketing enacted in response to the COVID-19 pandemic remain in effect, as described in the IPA’s recent update on October 7, 2020. As updates to this prohibition are being made on an ongoing basis, Approved Vendors and their Designees should monitor the Updates section of the ABP website for any changes.

Designee Registration Follow Up Questions from October 23, 2020 Webinar

The following questions were asked during the October 23, 2020 webinar for the new Designee registration functionality in the ABP portal and are answered below:

  • What prompted this change (requirement for Designees to register with the Program)?
    • Section 6.9.1 of the Revised Long-Term Plan published by the IPA on April 20, 2020, describes a new requirement for Approved Vendor Designees (i.e., third-party entities working with Approved Vendors that have direct interaction with end-use customers) to register and be listed on the ABP and Illinois Shines websites along with identifying the Approved Vendors with which they are working. The purpose of this new requirement is to increase transparency: potential customers will be able to verify that a company contacting that customer is indeed registered with the Program and be able to review if that company is listed in the Program’s consumer complaint database or the disciplinary actions report. All Designees will be added to the Program’s publicly facing Designee database once registered. This database will be housed on both the ABP and Illinois Shines websites for easy access.
  • Do installers of community solar have to register as designees (since they aren’t consumer-facing)?
    • No, because community solar installers do not have direct interaction with end-use customers they are not required to register as a Designee with the Program.
  • Who needs to register as an Approved Vendor Designee?
    • Every third-party entity that has direct interaction with end-use customers needs to register as a Designee. This includes:
      • DG Installers
      • Marketing firms
      • Lead generators
      • Sales organizations
  • Do third party companies working with Approved Vendors under Illinois Solar for All need to register as an Approved Vendor Designee?
    • Illinois Solar for All has a process for registering third-party entities that have direct interaction with end-use customers as ILSFA Aggregator Designees and subcontractors. More information about registering with Illinois Solar for All can be found here. ILSFA Aggregator Designees and subcontractors are not required to register as ABP Approved Vendor Designees.
  • If our company is an Approved Vendor but also operates as an Approved Vendor Designee for other Approved Vendors, do we need to submit an Approved Vendor Designee Registration?
    • If your company operates as a Designee but is also an Approved Vendor, you must also register as a Designee and identify those Approved Vendors or Designees with which you work.
  • Are Approved Vendor Designee registrations required at the company level or user level?
    • One account from each entity registering as a Designee is required. It is not required for all employees (or, in the case of sales personnel operating as independent contractors, each independent contractor) of the Designee to have their own Designee accounts.  The Program Administrator encourages Designees to only have one Designee account at the company level with an appointed person that is the contact for this Designee account on file with the Program.
  • What is a nested Designee?
    • A nested Designee is a Designee’s Designee (Approved Vendor > Approved Vendor Designee > Nested Designee), as opposed to an Approved Vendor Designee. All nested Designees that have direct interaction with end-use customers are required to register as Designees with the Program.
  • Where can I find the presentation slides and the webinar recording from the October 23rd training webinar?
    • These materials were sent out via email on Friday, October 23, 2020 and can also be found here:
    • What is the deadline for existing Designees to register with the Program?
      • New Designees must register prior to working with any Approved Vendor. Existing designees must register by Thursday, December 10, 2020 (which is 45 calendar days from the October 26, 2020 release of the Designee Registration functionality) to remain in compliance with Program requirements.
    • Our company is already linked to an Approved Vendor account as their Designee, do I still need to register as an Approved Vendor Designee?
      • Yes, all third-party entities that have direct interaction with end-use customers need to submit a registration using the new registration functionality, even if your company has already been operating as a Designee for an Approved Vendor in the Program. If your company is not registered as an Approved Vendor Designee by December 10, 2020, it will not be able to access functionality in the ABP portal.

If you have any further questions on this new Program requirement, please reach out to the Program Administrator at admin@illinoisabp.com or (877) 783-1820.

ABP Designee Registration Requirement and Functionality Training Presentation Recording and Slide Deck

A webinar to introduce the Designee registration functionality and provide training on how to use it was recorded October 23, 2020 to ensure that all entities are prepared to utilize the functionality before it goes live. Approved Vendors and Designees may access the recorded presentation and slide deck here.  Please note that answers to questions asked during the webinar will be posted next week by the Program Administrator.

New Designees must register prior to working with any Approved Vendor. Existing designees of an Approved Vendor must register by Thursday, December 10, 2020 (which is 45 calendar days from the October 26, 2020 release of the Designee Registration functionality) to remain in compliance with Program requirements.

Approved Vendors are responsible for ensuring that both their Designees and Designees of their Designees register with the Program. Approved Vendors who fail to do so may be subject to disciplinary action. For example, if an Approved Vendor has an installer as a Designee, and that installer hires a lead generation firm to assist with marketing, the Approved Vendor is responsible for ensuring that the lead generation firm (in addition to the installer) registers with the Program. One benefit to Approved Vendors through this system is that they will know which downstream firms are working with their direct Designees and may be able to better monitor those firms’ behavior, as the Approved Vendor ultimately is responsible that each of the entities under its umbrella complies with Program requirements.

Please reach out to the Program Administrator at admin@illinoisabp.com or (877) 783-1820 with any questions.

ABP Designee Registration Requirement and Functionality – Available on Monday October 26

Section 6.9.1 of the Revised Long-Term Plan published by the IPA on April 20, 2020 describes a new requirement for Approved Vendor Designees (i.e., third-party entities working with Approved Vendors that have direct interaction with end-use customers)  to register and be listed on the ABP and Illinois Shines websites along with the Approved Vendors with which they’re working. The purpose of this new requirement is to increase transparency for the Program. Potential customers will be able to verify that a company that reaches out to them is actually a Program participant registered with the Program (and likewise will be able to review if they are listed in the Program’s consumer complaint database or the disciplinary actions report). All Designees will be added to the Program’s publicly facing Designee database once registered. This database will be housed on both the ABP and Illinois Shines websites. The Program Administrator plans to release the functionality in the ABP portal that facilitates compliance with this requirement on Monday, October 26, 2020.

New Designees must register prior to working with any Approved Vendor. Existing designees of an Approved Vendor must register by Thursday, December 10, 2020 (which is 45 calendar days from the October 26, 2020 release of the Designee Registration functionality) to remain in compliance with Program requirements.

Once this functionality becomes available, all third-party entities that have direct interaction with end-use customers of the ABP and that operate within the Illinois Adjustable Block Program need to register as Designees on the Program website. Once registered, these entities can indicate in the portal one or more of the following Designee roles:

  • Disclosure Form Designee – An entity that is permitted to generate Disclosure Forms on behalf of an Approved Vendor.
  • Community Solar Subscriber Agent Designee – An entity that is permitted to manage the community solar subscription information for an Approved Vendor’s community solar projects.
  • Marketing or Sales Designee – An entity that is designated to act as a marketing agent and/or customer acquisition agent on behalf of an Approved Vendor or Designee. This includes, among others, entities that engage in solicitations through any channel (in-person, telephone, etc.), as well as entities that perform online lead generation services.
  • Installer Designee – An entity that has been designated to install systems on behalf of an Approved Vendor or Designee.

The IPA and Program Administrator reserve the right to add or remove roles as needed over time. Approved Vendors and Designees can add and remove Designees within their portal as needed. All registered Designees are only authorized to act in that designated role with Approved Vendors or Designees that have accepted it as a Designee and have not revoked that acceptance.

Failure by a Designee to comply with applicable Program requirements could subject the Designee to suspension or termination from registration. If the Designee ignores a suspension or termination decision made by the Program Administrator or the IPA and continues its market activity nonetheless, any Approved Vendor or Designee that works with the Designee during that period may be subject to discipline. Likewise, Approved Vendors and Designees found to be working with entities that fail to register as Designees with the Program may be subject to discipline.

Approved Vendors are responsible for ensuring that both their Designees and Designees of their Designees register with the Program. Approved Vendors who fail to do so may be subject to disciplinary action. For example, if an Approved Vendor has an installer as a Designee, and that installer hires a lead generation firm to assist with marketing, the Approved Vendor is responsible for ensuring that the lead generation firm (in addition to the installer) registers with the Program. One benefit to Approved Vendors through this system is that they will know which downstream firms are working with their direct Designees and may be able to better monitor those firms’ behavior, as the Approved Vendor ultimately is responsible that each of the entities under its umbrella complies with Program requirements.

A webinar to introduce the Designee registration functionality and provide training on how to use it has been scheduled for today October 23, 2020  at 1 PM Central Prevailing Time to ensure that all entities are prepared to utilize the functionality before it goes live. Approved Vendors and Designees may register for the webinar via the following link: https://us02web.zoom.us/meeting/register/tZYofu2oqjkvGtHYwGVr0wQku6H-4O1QsydL. If you are not able to attend this training webinar, it will be recorded and posted to the ABP website for easy access and review.

Please reach out to the Program Administrator at admin@illinoisabp.com or (877) 783-1820 with any questions.

Removal of the Standard Capacity Factors on November 5, 2020

The use of a standard capacity factor will be removed as an option for the method of production estimation used for applications in the ABP portal on November 5, 2020. After that date Approved Vendors will be able to select from the option of either a capacity factor calculated in the portal using PVWatts or proposing an alternative capacity factor. This change is being made to comport with the provisions of Section 6.14.5 of the Revised Long-Term Plan which removed references to the use of standard capacity factors (which had been an option in the Initial Long-Term Plan). This change will not impact project applications submitted prior to that date that utilized a standard capacity factor.

The removal of the standard capacity factors will become effective on November 5, 2020.

Designee Registration Portal Training – Friday Oct 23

Section 6.9.1 of the IPA’s Revised Long-Term Plan created a new requirement for Approved Vendor Designees (i.e., third-party entities working with Approved Vendors that have direct interaction with end-use customers) to register with the Adjustable Block Program. Designees may register under one or more of the following roles: Disclosure Form Designee, Community Solar Subscriber Agent, Installer, Marketing or Sales Organization.

The Program Administrator has created a new Designee registration functionality that is expected to be released through the ABP portal on Monday, October 26, 2020. A webinar to introduce this new functionality and provide training on how to use it will take place on Friday, October 23, 2020 at 1:00 PM Central Standard Time.

Please use the following link to register for the webinar: https://us02web.zoom.us/meeting/register/tZYofu2oqjkvGtHYwGVr0wQku6H-4O1QsydL

After registering, you will receive a confirmation email containing information about joining the meeting. If you are not able to attend this training webinar, it will be recorded and posted to the ABP website for easy access and review.

Please note that all Designees, that work within the ABP, must complete the designee registration no later than Thursday, December 10, 2020, which is 45 days from the release date of this functionality.

Revised DG Marketing Guidelines Reminder – Grace Period Ends October 31st

The revised Adjustable Block Program Distributed Generation Marketing Guidelines were published on September 16, 2020. These revised guidelines apply to all distributed generation sales and marketing activity from that date forward. Approved Vendors and those operating on their behalf are expected to be familiar with all changes and adhere to all requirements outlined in the revised guidelines.

As a reminder, there is a grace period of 45 calendar days from September 16, 2020 before disciplinary action is taken for violations of new, non-emergency requirements found in the revised guidelines. This grace period will end on October 31, 2020. This grace period only applies to items that have changed from the original DG Marketing Guidelines to the revised DG Marketing Guidelines.

Emergency restrictions against door-to-door marketing enacted in response to the COVID-19 pandemic remain in effect, as described in the IPA’s recent update on October 7, 2020. As updates to this prohibition are being made on an ongoing basis, Approved Vendors and their Designees should monitor the Updates section of the ABP website for any changes.

Updated COVID-19-Related Marketing Guidelines – October 7, 2020

On March 20, 2020, in light of the growing COVID-19 pandemic and its expected impacts in Illinois, the Illinois Power Agency adopted the following emergency amendment to its Adjustable Block Program and Illinois Solar for All Program Marketing Guidelines:

In-person marketing and solicitation: Given the public health emergency posed by the COVID-19 virus, in-person marketing or solicitation of photovoltaic system sales, installations, or financing; in-person marketing or solicitation of community solar subscriptions; or similar in-person solar marketing or solicitation activity are prohibited.

Clarifications to this prohibition were offered on May 19, 2020, along with additional guidance and updates on June 4, 2020, June 30, 2020, and August 5, 2020.

This update confirms that the IPA’s prohibition of door-to-door sales and solicitation remains in place while offering additional clarifications regarding the scope of this prohibition.

Regarding the basis for the IPA’s door-to-door sales prohibition, the statewide COVID-19 positivity rate (the percentage of positive tests across total tests given) remains in the range of 3.5%.  That positivity rate remains well above its lowest points from June and has showed little decline across the summer months, and the daily totals for both confirmed cases and fatalities in Illinois remain a significant public health concern.  As Illinois moves into cooler fall weather with more time spent indoors, efforts should be made to protect against a recurrent spike in COVID-19 transmission through curbing unnecessary—and especially unwanted—person-to-person contact.

The IPA believes that transactions benefitting from public funding should operate in the public interest.  Thus, in the interest of protecting public health, door-to-door sales remains a prohibited sales channel under solar incentive programs administered by the IPA (the Adjustable Block Program and Illinois Solar for All Program) and entities found violating this prohibition may be suspended from program participation.

CLARIFICATIONS

A reiteration of prior-offered clarification is provided below:

Passive forms of in-person marketing and solicitation – such as tabling at retail stores or events, or door-to-door distribution of marketing materials such as advertising flyers – are no longer prohibited.  While these activities could increase the likelihood of unnecessary person-to-person interactions, such an increase would be small or already agreed-to through participation in existing commercial channels.  Any permitted door-to-door distribution of marketing materials must consist only of distribution of materials (with no notification—such as door knocking or ringing of a doorbell—allowed as part of that distribution) and not include any other marketing or solicitation activities, including in-person sales or solicitation, until such time as the potential customer has received and read those materials and initiated an entirely separate follow-up conversation.

Additionally, in-person meetings with prospective or existing customers (such as a follow-up to an online or phone discussion) are not prohibited so long as expressly agreed to by that customer.  The IPA strongly discourages any high-pressure tactics used to secure such meetings, however, and requests that all Approved Vendors, designees, agents, and subcontractors strongly consider whether virtual meetings, e-signatures, or other telecommunication practices can instead be utilized.  Approved Vendors, designees, agents, and subcontractors must respect the wishes of existing or prospective customers who do not wish to meet in-person.

In addition to this prior-issued guidance the IPA offers the following additional clarifications:

  • This prohibition applies both to business-to-business sales in addition to sales to Illinois residents.
  • This prohibition applies to any size of system or subscription for photovoltaic systems benefitting from incentive funding through program participation.
  • While the term “door-to-door” is used in describing this prohibition, this prohibition applies to any attempts to initiate person-to-person contact without that person’s or business’s prior acquiescence, unless part of the tabling exception outlined above. Thus, approaching an individual on their property, on the street, or otherwise without their prior express consent to such person-to-person contact may constitute a violation.
  • Guidance offered by the Illinois Department of Commerce and Economic Opportunity (“DCEO”) regarding the permissibility of door-to-door sales during Phase 4 of the state’s Restore Illinois Plan addresses only whether such practices would run afoul of the Restore Illinois Plan, and does not address the requirements applicable to qualifying for state-administered incentive funding under the IPA’s programs.
  • Likewise, the removal of prohibitions on door-to-door solicitations by local governments does not impact program permissibility of door-to-door marketing for transactions funded through the IPA’s solar incentive programs in those areas.

For the foregoing reasons and those offered in its prior updates, the Agency believes this would be an inappropriate time to start permitting in-person interactions initiated without a customer, homeowner, or business owner’s express permission.  This prohibition will remain in effect until lifted by the IPA through a formal announcement, although the IPA will endeavor to continue providing updates.  Additionally, prior-issued guidance regarding best practices remains in effect.

Should you have questions about whether specific practices are permitted, please contact IPA Chief Legal Counsel Brian Granahan at Brian.Granahan@Illinois.gov.