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).
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.