Category: Stakeholder Comments

Comments on Second Draft Refreshed REC Contract Posted

As part of the implementation of the IPA’s Revised Long-Term Plan, a substantial refresh to the Adjustable Block Program REC contract is being conducted. On September 4, 2020, the IPA published a request for stakeholder comments regarding the Second Draft Refreshed REC Contract. Responses were due on September 18, 2020. The four comments the Agency received can be viewed here.

The Adjustable Block Program Administrator would like to thank all stakeholders that provided comments on the Adjustable Block Program’s Second Draft REC contract and will be announcing the next steps in the process shortly.

Request for Stakeholder Comments – Refreshed ABP REC Contract

The Illinois Power Agency is seeking feedback on the first draft of the refreshed Adjustable Block Program REC contract with comments due by August 14, 2020. The draft REC contract, a comparison of the draft REC contract and the current REC Contract, and a Request for Stakeholder Comments document can be found at www.illinoisabp.com/rec-contract. Please see the Request for Stakeholder Comments for additional background and information, and details on two virtual workshops scheduled for July 31, 2020 and August 7, 2020, both at 12:00 PM Central Standard Time.

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.

Updated Job Training and Workforce Diversity Comment Deadline

The deadline for submitting comments on the Request for Feedback for Job Training and Solar Workforce Diversity reporting requirements has been extended to Thursday, July 2, 2020. Please submit comments to admin@illinoisabp.com.

As part of this comment process, the Agency also requests that stakeholders provide comments on reasonable timelines and compliance periods for the submittal of diversity and job training information.

Finally, the opening of the Approved Vendor Annual Report portal is now planned for July 1, 2020 (as opposed to the June 22, 2020 date from the Request for Comments). As noted in the Request for Feedback, Annual Reports are due on July 15, 2020, but will not initially contain spaces for entry of diversity and job training information. Those categories will be added upon completion of this stakeholder feedback process.

Stakeholder Comments – REC contract

As part of the implementation of the IPA’s Revised Long-Term Plan, a substantial refresh to the Adjustable Block Program REC contract  is being conducted. On April 9, 2020 The Illinois Power Agency issued a request for comments on a refreshed REC contract for the Adjustable Block Program. Responses were due on May 12, 2020. The ten comments the Agency received can be viewed here.

The Adjustable Block Program Administrator would like to thank all stakeholders that provided comments on the  Adjustable Block Program REC contract, and will be announcing the next steps in the process shortly.

Ameren Illinois

Carbon Solutions Group

Central Road Energy

Certasun

ComEd

Cypress Creek Renewables

ENGIE

Joint Solar Parties

SRECTrade

Sustain Rockford

Stakeholder Comments on Marketing Guidelines, Community Solar Disclosure Form, and Application Batching Process

The Illinois Power Agency published three requests for stakeholder feedback in April 2020. The requests for comment regarding both the Marketing Guidelines and Community Solar Disclosure Form were announced on April 3, 2020 and due on April 28, 2020. The request for comments regarding the Adjustable Block Program Application Batching Process was published on April 15, 2020 and due on April 29, 2020.
You can view the stakeholder comments for both the Marketing Guidelines and Community Solar Disclosure Form, and for the Adjustable Block Program Application Batching Process below.

The Adjustable Block Program Administrator would like to thank all stakeholders that provided comments on the recent requests for comment about the Adjustable Block Program Marketing Guidelines, Community Solar Disclosure Form, and Application Batching Process.

Stakeholder Comments – Marketing Guidelines and Community Solar Disclosure Form

On April 3, the IPA published a request for feedback regarding the Illinois Adjustable Block Program Distributed Generation and Community Solar Marketing Guidelines, and the Community Solar Disclosure Form.

Comments were due Tuesday, April 28, 2020 at 5 PM Central Daylight Time. The comments submitted are linked below.

The Adjustable Block Program Administrator would like to thank all stakeholders that provided comments on the recent request for comments about the Adjustable Block Program Marketing Guidelines and Community Solar Disclosure Form.

Stakeholder Comments on ABP Application Batching Process

As a result of the ICC’s approval of the IPA’s Revised Long-Term Plan on February 18, 2020, changes to the Adjustable Block Program application batching process are required. On April 15, the IPA published a request for feedback regarding the batching process.

Comments were due Wednesday, April 29, 2020 at 5 PM Central Daylight Time. The four comments submitted are linked below.

The Adjustable Block Program Administrator would like to thank all stakeholders that provided comments on the recent request for comments about the Adjustable Block Program batching process.

Carbon Solutions Group

Engie

SRECTrade

Enertech