Category: General Program Information

Change to ABP Metering Requirements

The metering requirements for Adjustable Block Program projects have been updated as described in Section 6.12.2 of the IPA’s Revised Long-Term Plan. Previously, all systems registered in M-RETS were required to utilize an ANSI C.12 certified revenue grade meter regardless of system size. M-RETS has updated their operating rules to no longer require revenue grade meters and therefore the ABP metering requirements now reflect that change.

Systems registered in M-RETS now follow the same ABP metering requirements as applies to systems registered in GATS, which are as follows:

  • Systems over 25 kW must utilize a new meter that meets ANSI C.12 standards.
  • Systems over 10 kW and less than 25 kW in size must utilize a meter that meets ANSI C.12 standards. Meters that are refurbished (and certified by the meter supplier) are allowed.
  • Systems of 10 kW in size and below must utilize either a meter that is accurate to +/‐ 5% (including refurbished and certified meters), or an inverter that is specified by the manufacturer to be accurate to +/‐5%. The inverter must be UL‐certified and must include either a digital or web‐based output display.

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

Response to Comments: ABP Batching Process

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.

Tentative Timeline of Changes from the Revised Long-Term Plan

On February 18, 2020, the Illinois Commerce Commission approved the Illinois Power Agency’s Revised Long-Term Renewable Resources Procurement Plan, and the Agency published a final version of the Revised Plan on April 20, 2020. The Revised Plan includes a number of aspects of the Adjustable Block Program that will be updated or modified. In order to provide information on the implementation of those Program changes the IPA and Program Administrator present this list of Program modifications and expected completion dates. Completion dates are tentative and subject to change.

Final Revised Long-Term Renewable Resources Procurement Plan Posted

The Illinois Power Agency’s final Revised Long-Term Renewable Resources Procurement Plan has been posted. This page contains the final Revised Plan, filed Revised Plan, and initial Plan. Redlined versions that show the differences between the initial Plan and final Revised plan, as well as between the filed Revised Plan and final Revised Plan can be found on the page as well.

Group B Small DG Block 2 opening capacity

Upon the closure of Group B Small DG Block 1 on February 21, 2020 at 11:59 PM, the opening capacity of Group B Small DG Block 2 is 46.12 MWac.

The Program Administrator announced on February 22, 2020 that Group B Small DG Block 1 had closed. Per Section 1(C)(3)(b) of the Program Guidebook, this Block was held open for an additional 14 calendar days beyond the date on which it had reached capacity.  Any Group B Small DG applications submitted as part of a paid batch on or prior to February 21, 2020 at 11:59 PM Central Prevailing Time were allocated to Block 1, and thus received Block 1 pricing, provided that the application fee was paid within 10 business days following batch submittal. Any Group B Small DG applications submitted as part of a paid batch after that time will be allocated to Block 2.

The capacity allocated to Block 1 during this 14-day soft-close period impacts the capacity available for Block 2. Any applications submitted as part of a paid batch during the soft-close period that exceeded the original 52 MW capacity of Group B Small DG Block 1 were deducted from the original capacity of 52 MW for Group B Small DG Block 2. Because an additional 5.88 MW of capacity was allocated to Group B Small DG Block 1 during the soft-close period (for a total of 57.88 MW of Block 1 capacity), Group B Small DG Block 2 has an opening capacity of 46.12 MW, not the original capacity of 52 MW.

The final calculation of the opening capacity of Group B Small DG Block 2 was not known until at least 10 business days had passed from the closure of Block 1. Capacity allocated to projects in Group B Small DG Block 1 that are subsequently withdrawn will be added to Group B Small DG Block 2 capacity.

Group A Small DG Block 1 closed

Group A Small DG Block 1 is closed as of March 31, 2020 at 5:00 PM Central Prevailing Time and Group A Small DG Block 2 is now open.

The Program Administrator announced on March 25, 2020 that Group A Small DG Block 1 had reached capacity. Per Section 6.3.2 of the Revised Long-Term Plan, this Block was held open for an additional 7 calendar days.  Any Group A Small DG applications submitted as part of a paid batch on or prior to March 31, 2020 at 4:59 PM Central Prevailing Time were allocated to Block 1, and thus will receive Block 1 pricing, provided that the application fee is paid within 10 business days following batch submittal. Any Group A Small DG applications submitted as part of a paid batch after that time will be allocated to Block 2.

The capacity allocated to Block 1 during this 7-day soft-close period impacts the capacity available for Block 2. Any applications submitted as part of a paid batch during the soft close period that exceed the original 22 MW capacity of Group A Small DG Block 1 will be deducted from the original capacity of 22 MW for Group A Small DG Block 2. For example, if an additional 2 MW of capacity is allocated during the soft-close period (for a total of 24 MW of Block 1 capacity), Group A Small DG Block 2 will have an opening capacity of 20 MW, not the original capacity of 22 MW.

The Program Administrator will make a subsequent announcement with the preliminary calculation of the capacity available for Group A Small DG Block 2, factoring in the capacity allocated to Block 1 during its 7-day soft-close period. The final calculation of the opening capacity of Group A Small DG Block 2 will not be known until at least 10 business days have passed from the closure of Block 1. The Program Administrator will announce the opening capacity available for Group B Small DG Block 2 at that time. Capacity allocated to projects in Group A Small DG Block 1 that are subsequently withdrawn will be added to Group A Small DG Block 2 capacity.

Consumer Complaint Database posted

The Program Administrator announces that a Database of Consumer Complaints is now available on the Adjustable Block Program and Illinois Shines websites. The database provides a summary of complaints received by the programs and the status of their resolution. This report complements the previously released Disciplinary Actions Report and will be updated when changes occur to ensure that the information is up to date and serves as a reliable resource.

In addition, the Illinois Power Agency has filed the 2019 Consumer Complaints Report with the Illinois Commerce Commission. The report describes in more detail 28 complaints received by the Program Administrator between November 2018 and December 2019 as well as three disciplinary actions taken during that period. These complaints represent a very small portion of the over 11,000 project applications received.

In developing the Database and Report, the Illinois Power Agency and the Program Administrator have sought to balance respecting the privacy of complainants and the benefits of having transparent information that can be valuable to other consumers who may be seeking an Approved Vendor/Designee to work with. The Database and Report do not contain any personally identifying information regarding the complainant. (Background on stakeholder feedback on this topic can be found here.)

To be considered a consumer complaint, a complaint generally will need to come directly from the impacted consumer. However, the Program Administrator maintains the discretion to publish information on a complaint received from an ABP Approved Vendor/Designee or a third-party if the complaint provides information that would be valuable to other parties. Generally, complaints from an ABP Approved Vendor/Designee should be directed to the Program Administrator and will be addressed within the scope of the Program.

Reminders regarding energization extension requests and force majeure

The Illinois Power Agency and the Adjustable Block Program Administrator recognize that the COVID-19 crisis is creating uncertainties that could impact performance under Adjustable Block Program contracts. (See also the Agency’s March 20, 2020 announcement.)

Should Approved Vendors consider requesting extensions to energization deadlines and requests for force majeure, the Agency has the following procedural reminders.

Format

  • In general, requests should be made by submitting a formal letter on company letterhead in PDF format. Please include any applicable supporting documentation. Communicating that request by email is generally appropriate.
  • Please note that an energization deadline extension request is distinct from requesting the recognition of a force majeure event, and any request should clearly specify what relief is being requested and what specific clause of the contract is being invoked.

Energization deadline extensions

  • Several options for extension of energization deadlines are available; please see Section 5(b) of the REC Contract, starting on page 3.
  • Under Section 5(b), extension requests must be “made in writing by Seller to Buyer and the IPA.”  For the IPA, please email the request to IPA.Solar@illinois.gov.  For the Buyer, please refer to the contact sheet found within the contract itself.

Force Majeure

  • For any Approved Vendor seeking the recognition of a force majeure event under an Adjustable Bock Program REC delivery contract (see Article 6 as amended starting on page 30), the force majeure notification “must be made to both the Buyer and the IPA.”
  • In providing notification to the IPA, please email the request to IPA.Solar@illinois.gov.  For the Buyer, please refer to the contact sheet found within the contract itself.

 

Group A Small DG Block 1 capacity reached

The Illinois Power Agency (“IPA”) and Program Administrator announce that Block 1 for the Group A Small Distributed Generation (“DG”) project category (i.e. DG projects up to and including 10 kWac) has been filled. Block 1 will remain open for 7 calendar days per the soft-close provision in Section 6.3.2 of the Revised Long-Term Plan approved by the Illinois Commerce Commission on February 18, 2020.

Any Group A Small DG batches submitted prior to March 31, 2020 at 5:00 PM Central Prevailing Time will be allocated to Block 1, provided that the application fee is paid within 10 business days following submittal. Once the 7-day window of the soft-close has concluded, Block 1 will be considered closed and Block 2 will open. Any Group A Small DG applications submitted on or after March 31, 2020 at 5:00 PM Central Prevailing Time will be allocated to Block 2 and if verified will receive Block 2 REC pricing.

The Program Administrator will make another announcement on the date of the opening of Block 2 for Group A Small DG.

Group A Large DG Block 4 closed

On March 5, 2020 an application was submitted that exceeded the available capacity in Group A Large DG Block 4. This application and all other applications for this Group/category submitted in a paid batch on or prior to 11:59 PM Central Prevailing Time on that date were allocated to Block 4 up to a cap of 5 MW of additional Block 4 capacity. As previously announced on February 26, 2020, the application that crossed the 5MW cap was allocated to Block 4 in its entirety; as a result, the additional capacity allocated to Block 4 is 5.14 MWac. All subsequently submitted applications will be placed on a waitlist as the Block is now closed. At this time there is not a schedule for the opening of a future block of capacity for Group A Large DG. Please refer to the announcement of the Block 4 closing protocol on illinoisabp.com for more details.