Category: Community Solar

Posting of Stakeholder Feedback and Request for Updated Comments

On November 23, 2020 The Illinois Power Agency published the following requests for stakeholder feedback:

The stakeholder comments received regarding Project Selection for Future Community Solar Blocks are posted here.

The stakeholder comments received regarding REC Pricing for Future Adjustable Block Program Blocks are posted here.

The Illinois Power Agency and the Adjustable Block Program Administrator would like to thank all stakeholders that provided initial comments. If stakeholders would like to update their comments in light of any recent developments, or comment on other stakeholder’s comments, please provide those comments by February 8, 2021.

The Agency expects to release strawman proposals related to these in early March and will schedule virtual workshops to discuss those proposals at that time.

Please note that these feedback processes do not mean that the Agency is able to open new blocks of capacity for the Adjustable Block Program; as outlined extensively in Chapter 3 of the IPA’s Revised Long-Term Renewable Resources Procurement Plan, obtaining RPS funding necessary for opening additional blocks in 2021 would require passing new legislation, which has not happened to date.

Release of ABP Community Solar Subscriber Management Functionality

The Program Administrator has released subscriber management functionality for Approved Vendors that have ICC approved community solar projects and their CS Subscriber Agent Designees. This functionality facilitates the management of subscriber information for community solar projects in the ABP portal.

Please see a detailed explanation of the new subscriber management functionality that walks through the changes.

If you have any questions regarding this new portal functionality, please reach out to the Program Administrator at admin@illinoisabp.com or at 877-783-1820.

Implementation Schedule for the Revised Community Solar Disclosure Form

The Program Administrator previously solicited stakeholder input on proposed revisions to the Community Solar Disclosure form and on November 18, 2020 announced the final scope of nature of those changes. A template of the revised disclosure form was released December 8, 2020. The Program Administrator is currently programing the functionality to support the revised disclosure form and associated changes to the subscriber registration process in the Adjustable Block Program portal .

The Program Administrator is planning for a February 9, 2021 cutover in the ABP portal from the current Community Disclosure Form to the revised Community Solar Disclosure Form. This will include updated data fields and options, a new format for the generated form, and updated API and CSV upload functionality. In preparation for that cutover, the Program Administrator plans to release an updated version of the API to all API users on January 18, 2021 for beta testing, and to release a new version of the CSV upload guide on January 25, 2021.

Disclosure forms generated prior to the cutover date will remain valid, however any disclosure forms started in the portal but not completed (and thus generated for a subscriber signature) by the cutover date will need to be reentered after the cutover date in the updated portal in order to be completed and generated.

Implementation of additional API functionality to allow for the generation of the Revised Disclosure Form outside of the portal is expected to be released by February 23, 2021.

If you have any questions about the implementation schedule for the new Community Solar Disclosure Form, please email the Program Administrator at admin@illinoisabp.com or call 877-783-1820.

Revised Community Solar Disclosure Form Template

The Program Administrator previously announced on November 18, 2020 that it would release a template of the revised Community Solar Disclosure Form in advance of its implementation in the ABP portal. The revised version of the Community Solar Disclosure Form is not yet available for use but this template is provided here to give Approved Vendors and their Designees an idea of what the document will look like once it’s live. Please note that this is a single example of the document for which project specifications are provided. As the document contains dynamic text elements, other examples of the document may look different.

The template of the revised Community Solar Disclosure Form can be found here.

ABP Community Solar Waitlists Updated

Section 6.3.3.1.1 of the IPA’s Revised Long-Term Plan requires that for waitlisted community solar projects to remain on the waitlist, Approved Vendors would have to provide documentation of having maintained site control and any applicable land use permits. These documents were required to be submitted to the Program Administrator by May 18, 2020.

The Program Administrator has now completed its review of the documents submitted by Approved Vendors and has posted updated community solar waitlists to the ABP community solar dashboard page. As a result of this process, the Group A community solar waitlist has decreased from 450 projects to 357 projects and the Group B community solar waitlist has decreased from 347 projects to 304 projects.

The Program Administrator would like to thank all of the Approved Vendors who have responded over the past several months to requests for clarifications and additional verification documentation as part of the process to ensure that this was a comprehensive and complete review process.

Under Section 6.3.3.1.2 of the Revised Long-Term Plan, should funding become available to open new Adjustable Block Program blocks, 50% of any new community solar capacity will be allocated in accordance with the current ordinal community solar waitlists, for which these updated waitlists would be used. Please note that this does not mean that the Agency is planning to open new blocks of the Adjustable Block Program at this time. As outlined extensively in Chapter 3 of the Revised Long-Term Plan, obtaining RPS funding necessary for opening additional blocks in 2021 requires the passage of new legislation.

Requests for Stakeholder Feedback

The Illinois Power Agency has released the following two requests for stakeholder feedback.

Each document provides background on the request and poses a number of questions for stakeholder input.  Responses are requested by December 21, 2020 and instructions for how to respond is included in each document.  After these responses are received, the Agency expects to hold virtual workshops to discuss written feedback and seek additional feedback prior to finalization of any new selection criteria or prices.

*Please note that these feedback processes do not mean that the Agency is planning to open new blocks of the Adjustable Block Program; as outlined extensively in Chapter 3 of the IPA’s Revised Long-Term Renewable Resources Procurement Plan, obtaining RPS funding necessary for opening additional blocks in 2021 would require passing new legislation.

Adjustable Block Program Document Release Announcement

The Illinois Power Agency is pleased to announce to announce the finalization and release of revised versions of the following Adjustable Block Program documents:

The Agency also announces details for a revised edition of the following Adjustable Block Program document, with a final, usable version still pending:

These items were each the subject of prior stakeholder feedback processes, and the IPA thanks parties for the useful feedback offered through those comment periods, and for their patience as the Agency and Program Administrator finalized these documents.  Specific highlighted changes made to each of these documents are outlined below (please note that these are not a summary of all changes made to these program documents).

PROGRAM GUIDEBOOK

As the revised Program Guidebook is the first revised edition of the Guidebook since May 2019, it contains a collection of changes and updates reflecting program administration changes since the Program’s early days, including the deletion of now-stale content.  Other changes are intended to reflect the Illinois Commerce Commission’s Order in Docket No. 19-0995 approving the IPA’s Revised Long-Term Renewable Resources Procurement Plan, such as information on Designee registration.

Additional changes include a change in the threshold permissible DC:AC ratio for participating projects; that ratio is now 1.55, up from 1.5, to allow for more flexibility in system design.  Given the less permanent, more transactive nature of community solar subscription offers in the Illinois market, the Guidebook also now provides for guidance for how community solar providers will be able to generate and upload Community Solar Disclosure Forms outside of the Adjustable Block Program Portal (an item requested by many commenters during the most recent comment process).

A redline comparison of the original and revised Program Guidebooks is available on the Adjustable Block Program website.

COMMUNITY SOLAR MARKETING GUIDELINES

Similar to the recently-released revised Distributed Generation Marketing Guidelines, the revised Community Solar Marketing Guidelines have been reorganized into a more user-friendly, outline-driven structure.  Among the revisions include adjustments to the requirement that a standalone brochure be presented to customers at first contact; that brochure will be attached to the revised Community Solar Disclosure Form, with this now combined document required to be presented prior to subscription contract execution.

As with the Distributed Generation Marketing Guidelines, the Program is now making a logo available to Approved Vendors and Designees to signify that the entity is a firm registered with the program.  The process for obtaining approval for endorsements from governmental bodies, including municipal governments, has also been streamlined, with Program Administrator approval over each individual endorsement no longer required if predicate requirements are met.

As discussed further below, community solar providers will now have the flexibility to identify specific Approved Vendors and projects downstream (i.e., after disclosure form execution), and the revised guidelines provide requirements applicable to what content must be communicated to subscribers and by when should that option be utilized.

A redline comparison of the original and revised Community Solar Marketing Guidelines is available on the program website.

COMMUNITY SOLAR INFORMATIONAL BROCHURE

The Community Solar Informational Brochure has been updated with minor clarifying edits.  While this brochure will be integrated into the revised Community Solar Disclosure Form, until that revised disclosure form is finalized, community solar providers should begin to use this updated brochure instead of the original brochure released in January of 2019.  Furthermore, as described above, the brochure no longer needs to be presented at first customer contact, but can instead be presented in conjunction with the Community Solar Disclosure Form.

COMMUNITY SOLAR DISCLOSURE FORM

Consistent with feedback received in stakeholder comments, the revised Community Solar Disclosure Form has been shortened and streamlined.  As referenced above, the Community Solar Informational Brochure will now be included as an attachment to the disclosure form, and duplicative content already contained within the brochure has been deleted from the body of the disclosure form.  The revised form will also allow for flexibility in the identification of specific approved vendors and specific community solar projects: as before, a community solar provider may still input this information into the form, but now may alternatively elect a “TBD” input for those fields.

The net cash flow estimate section has been revised considerably.  In light of feedback regarding the inaccuracy of prior rendered savings estimates, this section has been changed to a narrative description outlining how customers can estimate the value of a community solar subscription through comparing subscription costs to supply rates (and thus to net metering credit rates).  This narrative description also now includes an example specific to a percentage-based savings subscription rate—which is how the IPA understands many offers to be structured in the community solar subscription market.

The Program Administrator is in the process of programing the changes required to allow for generation of the revised disclosure form.  A draft of the disclosure form text is being released contemporaneously with this announcement, in order to allow program participants to understand the types of changes that will be seen on the form and beginning planning for future implementation.  Within two weeks, the Program Administrator will release a template of the revised disclosure form. Subsequently, the Program Administrator will release additional programing information to allow community solar providers to plan for implementing programing changes related to the API and CSV upload options to accommodate the revised form.  This programming information release will include the API specifications for the option to generate (with Program Administrator pre-approval) disclosure forms outside of the ABP portal.  The Program Administrator expects that these changes will be in place by the end of the year for full implementation starting in 2021.

Update on Waitlisted ABP Community Solar Projects – Site Control Documentation and Land Use Permit Review

Section 6.3.3.1.1 of the IPA’s Revised Long-Term Plan required that Approved Vendors with waitlisted community solar projects provide documentation that those Approved Vendors have maintained site control and any applicable land use permits for waitlisted systems.  Those submittals were required by May 18, 2020.

This communication is merely to provide an update that the Program Administrator’s comprehensive review of documentation submitted has and that the review of submitted documentation is ongoing. The Program Administrator has completed review of projects’ submittals and anticipates completion of process by the end of September.  Once completed, and eligibility to remain on waitlists determined, the Program Administrator will release updated Group A and Group B community solar waitlists.

In the interim, please reach out to admin@illinoisabp.com or (877) 783-1820 with any questions.

Large DG and Community Solar waitlists posted

The Program Administrator has posted spreadsheets of the waitlists for the Group A Large DG and Group B Large DG categories on the Large DG dashboard page. Additionally, the Group A Community Solar and Group B Community Solar waitlists can be found on the Community Solar dashboard page. These files will be refreshed daily.

Please refer to the announcements on the Program website for more details on the closure of Group B Large DG Block 4 posted on March 5, 2020, the closure of Group A Large DG Block 4 posted on March 6, 2020, and the more general block closing protocol posted on February 26, 2020.

Section 6.3.3.1.1 of the Revised Long-Term Plan requires that waitlisted community solar projects, “will have to verify with the Program Administrator within 90 days of the approval of this Revised Plan that the project has maintained any applicable land use permits and site control (e.g., leases or lease options)” in order to remain on a waitlist. The Program Administrator will announce the process for this verification shortly.